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AFM calls on alternative investment fund managers and non-EU fund managers to submit AIFMD reports

The Dutch Authority for the Financial Markets (AFM) calls on alternative investment funds managers (AIFMs) to adhere to their AIFMD reporting obligation, and stresses that the AIFMD reporting obligation will also apply to non-EU fund managers.

Year-end reporting

Alternative investment fund managers are obliged to periodically report on their funds and management activities. The next deadline for the submission of reporting for Q4 2022, H2 2022 and Y1 2022 is 31 January 2023. Investment institutions with a ‘fund-of-funds’ strategy have until 15 February 2023 to submit their reports. The AFM expects all fund managers to submit correct reports by the relevant deadline. Year-end reporting is also mandatory for fund managers to which the ‘light registration regime’ applies.

Data quality (DQEF)

The year-end reports serve as source files for the annual Data Quality Engagement Framework (DQEF) review. The DQEF review enables the AFM to identify any inconsistencies in the reporting. The AFM will conduct this review in April 2023. As part of this review, the AFM may request fund managers to correct and resubmit their report. You can find more information on the DQEF review.

Frequency of the mandatory reporting

Every six months, after the reporting on Q2/H1 or Q4/H2/Y1 has been submitted, the AFM assesses whether the reporting frequency for the investment institutions or fund managers needs to be adjusted. The frequency of the mandatory reporting depends on the value of the assets under management (AUM) of the investment institutions managed by the fund manager, and on whether the fund manager uses leveraged financing. The AFM determines this reporting frequency with the aid of the decision tree (‘reporting obligation diagram’) in the ESMA’s Guidelines).

For new funds of a licensed fund manager, the AFM applies the basic principle – given the lack of reported data – that these funds must report each quarter. For new funds of a registered fund manager, an annual reporting frequency applies.

Non-EU fund managers

Notified fund managers and funds established outside the EU will be obliged to report to the AFM with effect from Q1 2023. These non-EU fund managers will be obliged to submit their first reports in April 2023. This concerns fund managers and funds with a notification under Section 1:13b(1) and (2) or Section 2:66 of the Dutch Financial Supervision Act (Wet op het financieel toezicht, Wft).

Non-EU fund managers will not be subject to the DQEF review in 2023, but they will be subject to this review from 2024.

Reporting via the AFM Portal

The AFM urges all fund managers established in countries outside the EU to create an AFM Portal account with access to Reporting in the near future, in order to prevent undesirable delays in reporting, and to enable the AFM to email them updates. Click for more information on creating an AFM Portal account, to learn more about submitting reports via the AFM Portal, and for the AIFMD reporting obligations.


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