AIFMD reporting
This page provides important information about the steps to be completed to ensure timely and correct submission of the reporting required under the Alternative Investment Funds Managers Directive (AIFMD). The Dutch Authority for the Financial Markets (AFM) recommends bookmarking this page and checking if it has been updated before filling in any reporting forms for a new reporting period.
Reporting obligations
The legal obligation to submit AIFMD reports applies from the first quarter following the inception date of the relevant AIF/AIFM and lasts through to the final reporting period in which the AIF/AIFM operates.
For example: an AIF/AIFM with the inception date 1 January 2020 and end date 1 January 2021 that is obliged to report annually must submit the following AIFMD reports: X2-2020 (for the period of 1 April 2020 to 31 December 2020) and Y1-2021 (for the period from 1 January 2021 to 31 December 2021). The AFM defines the inception date as the date of inclusion in its register and the end date as the date of deletion from its register. Make sure you cancel the AIF/AIFM in the AFM Portal in good time to prevent a reporting obligation being erroneously imposed on you.
In addition, the AFM periodically reviews the data quality of the submitted reports together with ESMA under the Data Quality Engagement Framework. This DQEF review concerns the last report submitted in the calendar year (Q4, H2, Y1 or X2) and is carried out annually in April, June and October. Following this review, you may be requested to re-report, i.e. to correct and resubmit your report. More information about this can be found in this sector letter.
Submission deadlines for reports
The submission deadline for AIFMD reports is one month after the end of the relevant reporting period, The AIFMD report for a fund-of-funds may be submitted up to 15 days later. Below is an overview of the legal deadlines for the submission of reports:
| Reporting period | End date | Submission deadline for manager/fund | Submission deadline fund-of-funds |
|---|---|---|---|
| Reporting period 1st quarter | End date 31 March | Submission deadline for manager/fund 30 April | Submission deadline fund-of-funds 15 May |
| Reporting period 2nd quarter, 1st half year | End date 30 June | Submission deadline for manager/fund 31 July | Submission deadline fund-of-funds 15 August |
| Reporting period 3rd quarter | End date 30 September | Submission deadline for manager/fund 31 October | Submission deadline fund-of-funds 15 November |
| Reporting period 4th quarter, 2nd half year, full year | End date 31 December | Submission deadline for manager/fund 31 January | Submission deadline fund-of-funds 15 February |
If you have an AFM Portal account with authorisations for ‘Reporting’, you will receive an email as soon as new reporting obligations arise for your company. Under ‘Reporting’ in the AFM Portal, you can also find your submission deadline and the status of your reporting obligations.
Submitting reports
AIFMD reports can be submitted under ‘Reporting obligations’ in the AFM Portal. Here, you will find an overview of your company’s reporting obligations and those of the investment funds managed by your company.If you click on this overview, you will see further information about these obligations and will be able to submit the relevant AIFMD reporting by uploading it. Please see our manual for instructions on how to optimally use this functionality in our AFM Portal.
If you do not yet have an account for the AFM Portal, you can register at the bottom of the AFM Portal login page. Click here for a manual on how to register and optimally set up your account in the AFM portal.
File format for reports
AIFMD reports must be submitted in XML format; we will not accept any other format. For every reporting obligation pending in the AFM portal, you must generate and submit a separate XML file containing only the data for the relevant reporting obligation. A reporting obligation may concern the fund manager or each individual fund, in which case each subfund qualifies as an individual fund. If you do not have the software needed to generate an XML file, you can obtain this software from an external supplier. Various market parties offer this software.
Processing time for the validation of reports
Status updates in the AFM Portal will only become visible after the user has pressed F5 to refresh the page. This also applies when multiple reports are uploaded simultaneously. The AFM’s validation of a submitted report usually only takes a few minutes. ESMA’s processing times can vary greatly, from around 5 minutes to more than 24 hours.
Processing times for AIFM reports are often shorter at the start of the submission period and in the evening, at night or in the early morning. They are often considerably longer near the end of the reporting period and in the late morning or afternoon, particularly for AIF reports. This is probably due to the fact that many fund managers submit their reports at the same time and submissions from all over Europe pile up in ESMA’s waiting queue.
Information about AIFMD reporting
The AFM sends information about the AIFMD reporting to users of the AFM Portal who have access to the AIFMD reporting. In addition, on our website and in our newsletters, we publish information about AIFMD reporting that is not only relevant to these users but also to other investment institutions.We recommend that you regularly check the page on our website where we publish news and the email account you use for the AFM Portal for new messages. On the news page, you can also subscribe to our AFM newsletters to ensure you do not miss any important messages from the AFM.
Frequently asked questions and useful documents
The AFM and ESMA have drawn up Q&As on the AIFM Directive, which also provide information about AIFMD reporting.
ESMA’s AIFMD reporting guidelines
- AIFMD – ESMA reporting guidelines
- AIFMD – Tables 1-7 of Annex 2 of ESMA Reporting Guidelines
- AIFMD – Tables 8-9-10 of Annex 2 of ESMA Reporting Guidelines
ESMA’s sample reports and technical guidance for AIFMD reporting:
- AIFMD – Reporting IT technical guidance (rev 5, including sample XMLs)
- AIFMD – Reporting – XML documents – V1.2
Frequently made errors in completing the reporting forms
Submitted AIFMD reports are regularly rejected by the AFM’s or ESMA’s validation process due to incorrectly entered data points. A validation file is sent for each report submitted. Below is a brief explanation of data points that are frequently entered incorrectly:
- Date notation: yyyy/mm/dd. This applies to a number of data points.
- ReportingPeriodStartDate: mandatory field. The value to be entered here for the reporting obligation is the first date mentioned under ‘Reporting period’ in the AFM Portal.
- ReportingPeriodEndDate: mandatory field. The value to be entered here for the reporting obligation is the last date mentioned under ‘Reporting period’ in the AFM Portal.
- ReportingPeriodType: mandatory field. The value to be entered here for the reporting obligation is the value shown in bold under ‘Reporting period’ in the AFM Portal (Q1, Q2, Q3, Q4, H1, H2, X1, X2 or Y1; so the value given in bold, without the year).
- FilingType: mandatory field. When you submit a report for the first time, the value you must enter here is ‘INIT’. If you have previously submitted a report that has already been approved by ESMA, you must enter ‘AMND’ when resubmitting the report. Please also note that, in order to resubmit a report that has already been approved by ESMA, you will first need to request the AFM (by sending an email to meldingenaifmd@afm.nl) to reopen the reporting obligation for you.
- ReportingMemberState: mandatory field. The value to be entered here for a report to the AFM is ‘NL’.
- AIFMJurisdiction: mandatory field. The value to be entered here for a report to the AFM is ‘NL’.
- AIFNationalCode: mandatory field. The value to be entered here for an AIF reporting obligation can be found under ‘Reference code’ in the AFM Portal.
- AIFMNationalCode: mandatory field. The value to be entered here for an AIFM reporting obligation can be found under ‘Reference code’ in the AFM Portal.
- LastReportingFlag: mandatory field. If you enter ‘true’ here, a report for a subsequent period will not be accepted by ESMA’s validation process. You should only enter ‘true’ here when submitting what is known as a ‘zero’ report. In all other cases, you would submit the last report in the subsequent period, when the activities of the AIF/AIFM have actually terminated.
- AIFNoReportingFlag: mandatory field. If you enter ‘true’ here, any information you enter in the AIFCompleteDescription field will not be accepted by ESMA’s validation process. This is also referred to as a ‘zero’ report, which is used when the fund does not yet have or no longer has any invested assets.
- AIFMNoReportingFlag: mandatory field. If you enter ‘true’ here, any information you enter in the AIFMCompleteDescription field will not be accepted by ESMA’s validation process. This is also referred to as a ‘zero’ report, which is used when you do not yet or no longer manage any assets.
- AIFContentType: mandatory field, in which you define the mandatory content of the AIF report. Fund managers with an AFM registration must enter ‘3’ for their funds here.
- AIFReportingCode: mandatory field, in which you define the type of fund you manage. Fund managers with an AFM registration must enter ‘1’ for their funds here.
- AIFMContentType: mandatory field, in which you define the mandatory content of the fund manager report. Fund managers with an AFM registration must enter ‘2’ here.
- AIFMReportingCode: mandatory field, in which you provide information about what type of fund manager you are. Fund managers with an AFM registration must enter ‘1’ here.
If you have questions about an error message issued by the AFM’s or ESMA’s validation process or any other question about AIFMD reporting that is not answered in the manual or in the reference documents on the ESMA website, please email it to meldingenaifmd@afm.nl.
Reporting obligation for third countries
Notified managers and funds from outside the EU will have to report to the AFM from Q1 2023. These managers will have to provide their first reports in April 2023.
To submit the reports it is necessary that you have an account for the AFM Portal. Information about creating an account and/or submitting reports via the AFM Portal can be found in the manual.
No data quality control (DQEF) will take place in 2023 on the reports submitted.
Any questions?
If you have any questions about the information provided above, please send an email to meldingenaifmd@afm.nl, including ‘AIFMD reporting’ in the subject line of your email.