AIFMD II implementation tracker: status by member state

Hundreds of AIFMD II summaries exist online. Nearly all were written on the day they were published. A 2024 "key changes" note will not tell you that Ireland transposed two weeks late. Nor will it say that the Commission adopted the liquidity-tools standards in November 2025, or that the new reporting template is not expected to go live before 2029.

AIFMD II is Level 1: the directive itself (Directive (EU) 2024/927), which sets the obligations in principle. Much of the operational detail sits in Level 2. That means the RTS/ITS (regulatory and implementing technical standards: binding technical rules that ESMA drafts and the Commission adopts). ESMA guidelines sit a level below, at Level 3: they guide consistent application without legislative change (ESMA final report, §134 to 135). A good part of AIFMD II's practical content is still at Level 2. That is why "AIFMD II applies from 16 April 2026" is true and incomplete at the same time.

Transposition is each member state writing the directive into its own national law. The directive binds governments. The national law is what binds a manager.

The full phase-in, with status as at 6 October 2026.

The member-state list comes from the EU's register of national transposition measures for Directive 2024/927, as at 6 October 2026. Member states supply that register and bear sole responsibility for it. It does not record the Commission's check of completeness. Some states notified older consolidated acts alongside their new amendments, so a count of measures says little about scope. The other notifiers are as follows.

• Bulgaria: two acts in Darzhaven Vestnik No. 71 of 7 Aug 2026.
• Croatia: amendments to its open-ended and alternative investment fund laws (NN 13/2026, 6 Feb 2026) and an ordinance (NN 27/2026, 18 Mar 2026).
• Czechia: 18 measures.
• Denmark: ten measures, including Lov nr. 1638 of 16 Dec 2025.
• Finland: the AIFM Act (162/2014) and the UCITS Act (213/2019), as last amended by 1444/2025 and 1445/2025 of 30 Dec 2025.
• Hungary: five measures, including Act C of 2025.
• Lithuania: five measures, including Law No. XV-294 of 30 Jun 2025.
• Romania: Law 243/2025 (Monitorul Oficial No. 1212, 30 Dec 2025) and ASF Regulation 2/2026 (10 Mar 2026).
• Slovakia: Act No. 85/2026, published 13 May 2026.

France has notified nothing. The AMF said in March 2026 that amendments to the Monetary and Financial Code, its General Regulation and its doctrine are to be expected (AMF, AIFM II).

Luxembourg

The Law of 3 March 2026 amends the UCI Law of 17 December 2010 and the AIFM Law of 12 July 2013. It started as Bill 8628. It was published in the Journal officiel, Mémorial A n° 115, on 9 March 2026, and Luxembourg transposed on time. Under its Article 57 it applies from 16 April 2026, except Article 16 and Article 42, points 1° and 2°, which apply from 16 April 2027 (Legilux).

The CSSF had the filing process open on the first day. LMT-selection filings were due by 16 April 2026 through eDesk, in a module open from 23 March. The LMT-activation module opened on 16 April 2026 (CSSF communication, 18 March 2026). Circular 25/901 of 19 December 2025 had already realigned the SIF, SICAR and Part II product framework (CSSF 25/901). From 21 September 2026 the activation module also takes suspensions of redemptions only. The CSSF states that such a suspension is not an LMT under the 2026 Law (CSSF communication, 18 September 2026).

Ireland

Ireland transposed late, through two instruments. The Minister for Finance made S.I. No. 181 of 2026 (AIFM) and S.I. No. 182 of 2026 (UCITS) on 28 April 2026. Notice of both appeared in Iris Oifigiúil on 1 May 2026, and both came into operation that day. Each defers one regulation to 16 April 2027, matching the directive's Article 3 carve-out. In S.I. 181 that is Regulation 14, which rewrites the reporting provision in Regulation 25 of the 2013 AIFM Regulations (S.I. 181/2026; S.I. 182/2026).

Between 16 April and 1 May, the directive's obligations existed at EU level but the Irish instruments were not yet in operation.

The Central Bank published its revised AIF Rulebook and the CP162 feedback statement on 5 May 2026. The revision goes beyond transposition and also carries Funds Sector 2030 recommendations. On loan origination, the Bank deleted the Rulebook's own "Loan Origination" section in favour of the AIFMD II regime. It removed the general restriction on QIAIFs granting loans and the restriction that kept RIAIFs from originating loans. It also limits registered and non-EU AIFMs to closed-ended loan-originating QIAIFs. Respondents asked for a 12-month transition, and the Bank replied that the revised AIFMD does not provide for one (CP162 feedback statement). A further update on 29 July 2026 amended Parts III and IV of Chapter 2 (CBI Markets Update 15/2026; AIF Rulebook).

The one-line read: Luxembourg landed on time with the filing process already open. Ireland landed two weeks late but used the same round to modernise its private-credit rules. Ten member states had notified nothing six months after the deadline.

UK

The UK is not transposing AIFMD II. It keeps its onshored AIFMD, the AIFM Regulations 2013 plus the FCA FUND sourcebook, while HM Treasury and the FCA design a replacement (FCA AIFMD (UK) page). The HM Treasury consultation and the FCA Call for Input closed on 9 June 2025 (HMT consultation; FCA CfI).

The next stage arrived on 14 July 2026. HM Treasury published a draft statutory instrument and policy note, with technical comments due by 14 October 2026 (HMT draft SI). The FCA published CP26/28 the same day. Most of its discussion chapters closed on 18 September 2026. The consultation chapters and the prudential discussion chapter close on 22 October 2026 after an extension. The FCA envisages implementation in 2028 (FCA CP26/28).

The direction is deregulatory, not convergent. The proposals replace AUM-based thresholds with NAV bands and proportionate rulebooks. The 2025 Call for Input proposed three bands: above £5bn, £100m to £5bn, and £100m or less. CP26/28 proposes keeping £5bn as the line for large AIFMs and raising the small-to-medium threshold to £750m NAV. That would give small (below £750m), medium (£750m to £5bn) and large (over £5bn) tiers (CP26/28, §2.4 to 2.11). UK AIFMs marketing into the EU are third-country managers under the new Article 42 conditions.

Jersey and Guernsey

Jersey and Guernsey are third countries, so AIFMD II does not bind them. AIFMD II rewrites the national private-placement conditions in Article 42. The old FATF non-cooperative test is deleted. In its place come two EU lists. The third country must not be an EU AML high-risk third country. Nor may it sit in Annex I of the EU list of non-cooperative tax jurisdictions. A tax information-exchange agreement with each marketing state is also required (Directive 2024/927).

Neither island, nor the UK, is on either list. They are not on the EU AML high-risk list under Delegated Regulation (EU) 2016/1675 as amended. Its latest amendments, Delegated Regulations (EU) 2026/46 and 2026/83, were published on 9 January 2026 and took effect on 29 Jan 2026 (EU AML high-risk list (Commission)). Nor are they in Annex I (or Annex II) of the EU tax list as updated by the Council on 17 Feb 2026 (EU tax list (Commission)). Both lists move on their own cycles, so recheck them before an NPPR filing.

Jersey has written AIFMD II into its own rulebook. The JFSC's Alternative Investment Funds Code of Practice, EU/EEA regime, is titled "transposing EU AIFMD II" and is "effective from 16 April 2026". Its glossary reads the Level 1 AIFM Directive as Directive 2011/61/EU and/or Directive (EU) 2024/927. It applies to AIFMs "managing an EU AIF, or who are marketing a Directive AIF in the European Union or EEA", and to Jersey depositaries. That covers AIF certificate holders, AIF services businesses under the Financial Services (Jersey) Law 1998 and sub-threshold managers approved under the AIF Order. A Full Passport AIFM takes the full Code. A Private Placement AIFM takes paragraph 25, parts of Section 1 and the Section 3 transparency rules; the Section 4 company-control rules apply where paragraph 20.1 catches the fund. From the same date the 2021 AIF Code "only applies to the UK-focused regime".

In short, a Guernsey manager watches the Article 42 lists. A Jersey manager marketing into the EU watches the same lists and applies the EU/EEA Code.

Loan origination: the largest structural change

AIFMD II inserts an EU-wide regime into Article 15 AIFMD for AIFs that originate loans. Leverage is capped at 175% of NAV for open-ended and 300% for closed-ended loan-originating AIFs (commitment method). A 20% concentration limit applies per borrower where the borrower is a financial undertaking, an AIF or a UCITS. Under Article 15(4i), the AIF must retain 5% of the notional value of each loan it has originated and then transferred to third parties. Originate-to-distribute strategies are banned (Directive 2024/927).

The 5% is held until maturity for loans of up to eight years and for all consumer loans, and for at least eight years for other loans. It does not apply when the AIF sells assets to redeem investors in a liquidation. Nor does it apply to a sale needed to comply with Article 215 TFEU restrictive measures or product requirements. The same goes for a sale that implements the AIF's investment strategy in investors' best interests, or follows a deterioration in the loan's risk disclosed to the buyer. On request, the AIFM must show its regulator that the derogation applies (Directive 2024/927, Art 15(4i) as inserted).

Loan-originating AIFs are closed-ended unless the AIFM can show a liquidity system compatible with an open-ended structure. The detail of that test sits in the ESMA RTS, which the Commission has not adopted (ESMA final report, Oct 2025). In its final draft, ESMA dropped the prescriptive minimum-liquid-asset bucket in favour of an outcome test. It also cut the required stress-testing frequency from quarterly to at least annual.

Grandfathering carries most existing credit funds, under Article 61(6) AIFMD as inserted (Directive 2024/927). An AIF constituted before 15 April 2024 that raised no further capital after that date is deemed compliant with Article 15(4a) to (4d) and Article 16(2a) indefinitely. One that kept raising capital is deemed compliant only until 16 April 2029. Until then, where the loans to a single borrower or the leverage already exceed the Article 15(4a) or (4b) limit, the manager may not increase that value or that leverage. Where they are below the limit, it may not take them above it. Loans originated before 15 April 2024 stay outside Article 15(3)(d) and (4e) to (4i). A manager may opt in early by notifying its home regulator.

Liquidity management tools: live now, with a filing attached

An AIFM subject to Article 16 selects at least two LMTs for each open-ended AIF it manages. Every UCITS must do the same. Registered sub-threshold AIFMs under Article 3(2) are outside this duty unless they opt in under Article 3(4) (consolidated AIFMD, Arts 3 and 16(2b)). The tools come from the harmonised list in points 2 to 8 of the new Annex V to the AIFMD, or Annex IIA to the UCITS Directive. Both annexes number the tools the same way. The list covers gates, extension of notice periods, redemption fees, swing pricing, dual pricing, anti-dilution levies and redemption in kind. Suspension (point 1) and side pockets (point 9) are available in addition and do not count toward the two. Money market funds may select just one. Redemption in kind is restricted to professional investors. A selection made up only of swing pricing and dual pricing is not accepted (Directive 2024/927, Art 16(2b) AIFMD and Art 18a(2) UCITS; CSSF communication). Activation and deactivation of certain tools must be notified to the home regulator.

The Level 2 detail on what each tool must look like is in two delegated regulations. They are Delegated Regulation (EU) 2026/465 (AIFMD) and (EU) 2026/466 (UCITS). The Commission adopted them on 17 November 2025 and they were published in the Official Journal on 27 February 2026. Both entered into force on 19 March 2026 and apply from 16 April 2026. Funds constituted before 16 April 2026 are deemed compliant until 16 April 2027. They may opt in earlier by notifying their home regulator (EUR-Lex 2026/465; EUR-Lex 2026/466).

ESMA's guidelines on selecting and calibrating the tools were revised in a December 2025 report and published on 12 March 2026. They apply from the RTS application date, 16 April 2026. For funds existing before that date they apply twelve months later, on 16 April 2027 (ESMA guidelines, ESMA34-671404336-1364). Luxembourg turned the selection into a dated eDesk filing, due 16 April 2026. Ireland folded the equivalent into the revised Rulebook and the CP162 feedback.

Delegation and substance: notification now, data later

Delegation survives, and the directive expressly keeps the model workable. It does add procedure. A manager gives fuller notice of delegation arrangements at authorisation. The delegation rules extend to all Annex I functions and ancillary services. A minimum of two full-time natural persons domiciled in the EU must conduct the business. The item most often overlooked is delegation data inside supervisory reporting: who the delegates are, what was delegated and how much of the portfolio. That arrives with the 2027 reporting date, not in 2026. ESMA reports on delegation practices by 16 April 2029 (Directive 2024/927).

Supervisory reporting: two dates years apart

The reporting amendments are the one block that Article 3 defers to 16 April 2027. They cover Article 24 AIFMD and a new Article 20a UCITS, the first UCITS supervisory reporting regime. The scope widens. Managers report on the instruments they trade, the markets they trade on, and each fund's exposures and assets, no longer only the "principal" ones. Delegation arrangements and the full liquidity picture are added (Directive 2024/927, Art 1(12)).

The templates that give this shape come later. ESMA must submit draft RTS/ITS to the Commission by 16 April 2027 (Article 24(5a) and (5b) AIFMD as amended), after a consultation paper later in 2026. It expects go-live in the first half of 2029 at the earliest. ESMA recommends that existing templates continue until the new ones replace them (ESMA final report, §146 to 152). The Annex IV reporting guide covers today's filing.

Open-ended loan-originating AIF RTS. The Commission wrote to the ESAs on 1 October 2025, in a letter published on 6 October 2025. It said it will not adopt 115 "non-essential" Level 2 empowerments before 1 October 2027. The annex lists the "RTS on open-ended Loan Originating Funds" by name, as item 45 (Commission, de-prioritisation of Level 2 acts). The same annex lists two ITS under Directive 2024/927 on information exchange between authorities (items 111 and 112). In the meantime, open-ended credit funds run on the Level 1 test alone. The Central Bank of Ireland cited the unadopted RTS when it declined to let non-EU AIFMs manage open-ended loan-originating QIAIFs (CP162 feedback statement).

LMT guidelines. National regulators had two months from ESMA's publication to notify whether they comply or intend to comply, with reasons for any non-compliance (ESMA guidelines, §10).

Costs report. ESMA published its Report on total costs of investing in UCITS and AIFs (ESMA50-1949966494-3918) on 6 November 2025. It went to the Parliament, Council and Commission under Art 12 AIFMD and Art 14 UCITS as amended. It feeds the Commission's retail-cost work.

Reporting standards. ESMA's AIFMD reporting page still describes the current regime. The AIFMD II timetable comes from the final report of 4 May 2026.

Three practical points follow. First, the deadline split into three. 16 April 2026 brought the conduct rules, LMT selection and loan-origination limits. 16 April 2027 brings reporting, plus LMT-RTS conformance for existing funds. 16 April 2029 ends the credit-fund grandfathering and brings the delegation review. Budget them as three projects, not one.

Second, transposition lag is real. Ireland's instruments arrived on 1 May 2026, and ten member states had notified nothing by October 2026 (EUR-Lex). If you documented AIFMD II compliance decisions for an Irish AIFM in the last two weeks of April, note which legal basis you relied on at the time. The same applies in any late member state.

Third, the UK divergence cuts both ways. UK managers escape AIFMD II's obligations but keep none of its rights. Into the EU they are third-country managers under the new Article 42 conditions, exactly like a Jersey or Guernsey manager. Their domestic rulebook is being rebuilt on a different structure (FCA CP26/28).

On reporting, the obligation and the template now sit years apart. The amended Article 24 applies from 16 April 2027, while ESMA expects the new template to go live in 2029 at the earliest. Ask your Annex IV vendor for an AIFMD II gap analysis once the ESMA consultation is published.