Alternative Investment Fund Managers Directive 2 (AIFMD 2)

Directive on Undertakings for Collective Investment in Transferable Securities 6 (UCITS 6)

Directive (EU) 2024/927 amending Directives 2011/61/EU and 2009/65/EC as regards delegation arrangements, liquidity risk management, supervisory reporting, the provision of depositary and custody services and loan origination by alternative investment funds

Finetuning of the AIFMD and targeted amendments to the UCITS Directive

Level 1

Entry into force

16 April 2024

2025

16 April 2025

Level 2

Open-ended loan-originating AIFs

ESMA to develop draft regulatory technical standards to determine the requirements with which loan-originating AIFs are to comply in order to maintain an open-ended structure. Those requirements must include a sound liquidity management system, the availability of liquid assets and stress testing, as well as an appropriate redemption policy having regard to the liquidity profile of loan-originating AIFs. Those requirements shall also take due account of the underlying loan exposures, the average repayment time of the loans and the overall granularity and composition of the portfolios of loan-originating AIFs.

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Update 12 December 2024: ESMA issued a consultation paper on draft regulatory technical standards on open-ended loan-originating AIFs. The consultation closed for feedback on 12 March 2025.

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Update 6 March 2025: ESMA delayed the development of these draft regulatory technical standards by 6 months.

ESMA consults on draft regulatory technical standards for loan-originating AIFs (19 December 2024)

16 April 2025

Level 2

Liquidity management tools

ESMA to develop draft regulatory technical standards specifying the characteristics of the liquidity management tools set out in annex V of the amended Directive 2011/61/EU, known as the AIFMD, respectively set out in annex IIA of Directive 2009/65/EC, known as the UCITS Directive.

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Update 15 April 2025: ESMA published the draft regulatory technical standards. The EU Commission has now three months to decide whether to adopt the draft regulatory technical standards. Following adoption, the EU Parliament and the Council of the EU will scrutinise the text of the regulatory technical standards.

16 April 2025

Level 3

Liquidity management tools

ESMA to develop guidelines on the selection and calibration of liquidity management tools by AIFMs and by UCITS for liquidity risk management and for mitigating financial stability risks. The guidelines must recognise that the primary responsibility for liquidity risk management remains with AIFMs, respectively the UCITS. They must include indications as to the circumstances in which side pockets can be activated.

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Update 15 April 2025: ESMA published a final report on its guidelines on liquidity management tools. ESMA will translate the guidelines following the adoption of the draft regulatory technical standards by the EU Commission. Should the EU Commission amend the draft regulatory technical standards in a way that impact the guidelines, ESMA will adjust the guidelines to ensure full consistency. The guidelines will start applying on the date of entry into force of the regulatory technical standards. Funds existing before the entry into force the regulatory technical standards will have twelve months to comply with the guidelines.

16 October 2025

Milestone

Costs

ESMA to submit a report to the EU Parliament, the Council of the EU and the EU Commission assessing the costs charged by AIFMs, UCITS and UCITS management companies to investors and explaining the reasons for the level of those costs and for any differences between them, including differences resulting from the nature of the AIFs and UCITS concerned. As part of that assessment, ESMA must analyse, within the framework of Article 29 of Regulation (EU) No 1095/2010, the appropriateness and effectiveness of the criteria set out in the ESMA convergence tools on the supervision of costs.

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Update 14 November 2024: Together with the national competent authorities, ESMA launched a data collection exercise on costs linked to investments in AIFs and UCITS (14 November 2024).

Level 1

Implementation and application

16 April 2026

Member States to adopt and publish the laws, regulations and administrative provisions necessary to comply with Directive (EU) 2024/927. Member States must apply the new measures, with the exception of the amended reporting obligations to competent authorities (measures implementing the amendments under Article 24 of the amended AIFMD, respectively under new Article 20a of the amended UCITS Directive), which they must apply from 16 April 2027.

2026

16 April 2026

Level 3

Supervisory coordination concerning LMTs

ESMA to develop guidelines providing indications to guide the competent authorities in their exercise of the powers to require the activation or deactivation of liquidity management tools (Article 46(2), point (j) of the amended AIFMD; Article 84(2)(b) of the amended UCITS Directive), and indications as to the situations that might lead to the respective requests from the competent authorities of host Member States (Article 50(5b) and (5f) of the amended AIFMD; Article 98(3) of the amended UCITS Directive). Those guidelines must recognise that the primary responsibility for liquidity risk management remains with AIFMs and UCITS.

16 April 2026

Level 3

Fund names

ESMA to develop guidelines specifying the circumstances in which the name of an AIF or an UCITS is unfair, unclear or misleading. The guidelines must take into account relevant sectoral legislation. Sectoral legislation for fund names or marketing of funds takes precedence over the guidelines.

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Update 6 March 2025: ESMA delayed the development of these guidelines by at least 12 months.

16 April 2026

Milestone

Supervisory data

ESMA to submit to the EU Commission a report regarding the development of integrated collection of supervisory data, which must focus on how to:

  • reduce areas of duplication and inconsistencies between the reporting frameworks in the asset-management sector and other sectors of the financial industry; and
  • improve data standardisation and efficient sharing and use of data already reported within any Union reporting framework by any relevant competent authority, at Union or national level.

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Update 23 June 2025: ESMA issued a discussion paper to gather feedback on how to integrate fund reporting, with the aim of reducing the burden for market participants. The consultation closes for feedback on 21 September 2025.

Level 1

Application

16 April 2027

Member States to apply the measures on reporting obligations to competent authorities (amended Article 24 of the AIFMD and new Article 20a of the UCITS Directive).

2027

16 April 2027

Level 2

Supervisory reporting

ESMA to develop draft regulatory technical standards specifying

  • the details of the information to be reported;
  • the appropriate level of standardisation for the information to be reported;
  • the reporting frequency and timing.

16 April 2027

Level 2

Supervisory reporting

ESMA to develop draft implementing technical standards specifying

  • the format and data standards for the reports referred to in Article 24(1) and (2) (Reporting obligations to competent authorities) of the amended AIFMD and in Article 20a(1), (2) and (4) of the amended UCITS Directive;
  • the identifiers that are necessary to connect the reported data on assets, AIFMs, AIFs, UCITS and UCITS management companies to other supervisory or publicly available data sources;
  • the methods and arrangements for submitting the reports, including methods and arrangements to improve data standardisation and efficient sharing and use of data already reported in any EU reporting framework by any relevant competent authority, at EU or national level, taking into account the findings of the issued report;
  • the template, including the minimum additional reporting requirements, to be used by AIFMs and by UCITS management companies in exceptional circumstances as referred to in Article 24(5) of the AIFMD and in Article 20a(4) of the UCITS Directive.
2028

15 April 2028

Level 2

UCITS Directive only: delegation

EU Commission to adopt delegated acts specifying:

  • the conditions for fulfilling the requirements set out in Article 13(1) of the amended UCITS Directive;
  • the conditions under which the management company is to be deemed as having delegated its functions to the extent that it becomes a letter-box entity and can no longer be considered to be the manager of the UCITS or the provider of the services referred to in Article 6(3) of the amended UCITS Directive, as set out in Article 13(2) of the amended UCITS Directive.

No specific timeline

Level 2

AIFMD only: leverage

EU Commission to adopt delegated acts specifying when leverage is to be considered as being employed on a substantial basis for the purposes of Article 24(4) (Reporting obligations to competent authorities) of the amended AIFMD.

2029

16 April 2029

Milestone

Delegation framework

ESMA to provide the EU Parliament, the Council of the EU and the EU Commission with a report analysing market practices regarding delegation and compliance, based, inter alia, on the data reported to the competent authorities and on the exercise of ESMA’s supervisory convergence powers. The report must also analyse compliance with the substance requirements.

16 April 2029

Milestone

AIFMD only: review of AIFMD

Following the report produced by ESMA on the delegation framework, EU Commission to initiate a review of the functioning of the rules laid down in the AIFMD and the experience acquired in applying them. The review must include an assessment of the following aspects:

  • the impact on financial stability of the availability and activation of liquidity management tools by AIFMs;
  • the effectiveness of the AIFM authorisation requirements as regards the delegation regime, in particular with regard to preventing the creation of letter-box entities in the EU;
  • the appropriateness of the requirements applicable to AIFMs managing AIFs which originate loans;
  • the functioning of the derogation allowing the appointment of a depositary established in another Member State and the potential benefits and risks, including the impact on investor protection, financial stability, supervisory efficiency and availability of market choices, of amending the scope of that derogation, in line with the objectives of the capital markets union;
  • the appropriateness of the requirements applicable to AIFMs managing an AIF at the initiative of a third party and the need for additional safeguards to prevent circumvention of those requirements, and, in particular, whether the provisions of the AIFMD on conflicts of interest are effective and appropriate in order to identify, manage, monitor and, where applicable, disclose conflicts of interest arising from the relationship between the AIFM and the third-party initiator;
  • the appropriateness and impact on investor protection of the appointment of at least one non-executive or independent director to the governing body of the AIFM, where it manages AIFs marketed to retail investors.

16 April 2029

Milestone

UCITS only: review of UCITS Directive

Following the report produced by ESMA on the delegation framework, EU Commission to initiate a review of the functioning of the rules laid down in the UCITS Directive and the experience acquired in applying them. That review must include an assessment of the following aspects:

  • the effectiveness of the authorisation requirements in Articles 7 and 8 of the UCITS Directive as regards the delegation regime laid down in Article 13 of the UCITS Directive, in particular with regard to preventing the creation of letter-box entities in the EU;
  • the appropriateness and impact on investor protection of the appointment of at least one non-executive or independent director to the management body of the UCITS management companies or investment companies;
  • the appropriateness of the requirements applicable to management companies managing a UCITS at the initiative of a third party and the need for additional safeguards to prevent circumvention of those requirements, and, in particular, whether the provisions of the UCITS Directive on conflicts of interest are effective and appropriate in order to identify, manage, monitor and, where applicable, disclose conflicts of interest arising from the relationship between the management company and the third-party initiator.