AIFMD Annex IV reporting: frequency, template, deadlines

Every EU or UK AIFM managing or marketing an alternative fund reports to its regulator. The periodic transparency report is a duty under Article 24 of the AIFMD, or Article 3 for sub-threshold "registered" managers. The industry calls the file Annex IV, after the annex of the Level 2 Regulation that lists the data points. The vendor guides that rank for this search are selling their filing engine. This page is a neutral how-to. It covers how your reporting frequency is set, what sits in the file, how each regulator wants it delivered, and what causes errors for first-time filers. It also covers what replaces the template: AIFMD II on the EU side, and a separate UK framework that has started to pull away from it. For the deadline dates across Luxembourg, Ireland, the UK, Jersey and Guernsey, the sibling page holds the table: the 2026 regulatory calendar.

The regime is harmonised at template level. The same ESMA XML schema, the same data points and the same AuM-driven frequency logic apply in Luxembourg, Dublin and London. The UK onshored them almost verbatim after Brexit. What differs is the filing mechanics: the portal, the upload steps and the local validation layer. Most of this guide is therefore domicile-neutral, and the per-NCA table isolates what changes by regulator. On the UK side, that harmonisation may now end. In July 2026 the FCA consulted on retiring the Annex IV data items altogether in favour of a domestic framework (below). This is the last stretch in which "one file, three regulators" fairly describes the job.

Almost every operational rule below comes from one of three sources. Knowing which one settles the question. Article 110 of the Level 2 Regulation (Commission Delegated Regulation 231/2013) sets frequency and deadline. ESMA's reporting guidelines (ESMA/2014/869) set procedure: first reports, frequency changes, structures and liquidations. Your NCA's own guidance sets filing mechanics: portal, file names, sign-off and local validation. When a vendor says "the regulator requires X", ask which of the three sources X comes from.

• Authorised (full-scope) AIFMs file the full Article 24 report at AIFM level, plus one AIF-level report per fund managed or marketed.
• Registered (sub-threshold or "de minimis") AIFMs sit below the AIFMD thresholds: €100m including leverage, or €500m unleveraged with no redemption rights exercisable for 5 years. They still report under Article 3(3)(d), but on a lighter set of fields and, in the base case, only once a year. That lighter set is three limbs of one paragraph. Knowing it precisely is the difference between a week's work and a quarter's. ESMA Guidelines 2014/869
• Non-EU AIFMs marketing under a national private placement regime (NPPR) report to each NCA in whose jurisdiction they market, under Article 42. Each NCA's report covers the AIFs marketed in that Member State. Where the Member State applies ESMA's Article 24(5) opinion, the report also covers unmarketed master AIFs of those feeders. ESMA AIFMD Q&A, Section III Q1

Frequency is not a choice. It follows from assets under management and from whether the fund uses leverage. AuM here is measured on the AIFMD "regulatory" basis, which is not NAV: derivatives count at their converted-to-underlying value. The bands sit in Article 110(3) of the Level 2 Regulation as four separate limbs. Two classify the manager and two classify an individual fund. That structure is easy to overlook, and it means your AIFM-level and AIF-level reports can land on different frequencies. Commission Delegated Regulation (EU) No 231/2013, Art. 110(3) · UK assimilated text of Art. 110

Know this before you build anything permanent around these bands. ESMA has now recommended replacing the whole AuM-driven frequency structure with a monthly base frequency, calibrated module by module rather than fund by fund. That change is years away, and you file on the bands above today. It is still the reason not to hard-wire "quarterly or half-yearly" into a new reporting system. The horizon section has the detail and the dates.

Reference dates run on the TARGET calendar. Reporting periods end on the last business day of March, June, September and December. Quarterly filers report as of all four dates. Half-yearly filers report as of the last business day of June and December. Annual filers report as of the last business day of December. ESMA Guidelines 2014/869, §8

Ireland's portal labels returns differently. The Central Bank's reporting date is 31 March, 30 June, 30 September or 31 December, whatever the weekday or holiday. Its submission due date is the last calendar day of the following month: 30 April, 31 July, 31 October or 31 January. A 30 September return is therefore due 31 October. A fund of funds may add 15 calendar days. Use the TARGET business day for the data and the Bank's calendar date on the Irish return. CBI Reporting Guidance for AIFMs, General Notes §6 and Reporting Date.

Five points the decision flow does not show:

• Reference dates are the last business day of the period, not the calendar quarter-end. Your data snapshot date moves with the calendar each year, so do not hard-code 30 June or 31 December. If that last business day is a bank holiday in your jurisdiction and no data is available, use the previous business day's information. Under the ESMA guidelines, keep the TARGET date as the reporting date. The data moves; the label does not. The Irish portal is the exception: it takes the calendar quarter-end date (above). Guidelines §9
• The submission deadline is "as soon as possible and not later than one month" after the end of the reporting period. The data date and the deadline are different things. The Q4 or annual report is due at the end of January. Where the AIF is a fund of funds, the AIFM may extend that period by 15 days, because it needs its underlying funds' data first. Both sentences sit in Article 110(1). For UK filers, both survive verbatim in the assimilated UK text. Art. 110(1)
• For a mixed book, the fund-of-funds extension does not delay the manager's report. It duplicates it. The FCA's worked examples apply the 15 days to both AIF001 and AIF002 where the AIF is a fund of funds (FCA Q&A, Q4). The FCA sets out a separate sequence for a manager that runs both fund-of-funds and ordinary AIFs and takes the extension. At the one-month deadline, you file the AIFM report and the AIF reports for every fund that is not a fund of funds. Before the extended date, you file the fund-of-funds AIF reports and an amended AIFM report that reflects the fund-of-funds figures. Claiming the extension therefore costs a second manager-level filing. Budget for it early, not in the last fortnight of the month. FCA Annex IV Q&A, Q5
• Your NCA can raise the frequency. Article 110 lets the competent authority require all or part of the information more often where it deems that necessary. The Regulation sets your floor, not a ceiling.
• Frequency can step up or down mid-life. If AuM crosses a threshold, you change band. Your first report on the new frequency may cover several elapsed periods. You send one report for them, not one per period. The guidelines tabulate every possible transition in Tables 8 to 10. Read the worked cases once before your first change, not during it. Guidelines §17 to 32

How is the AuM figure calculated, monitored and breached?

Every band above hangs off one figure, and the Regulation does not leave that figure to you. Four articles at the front of Regulation 231/2013, a hundred articles before Article 110, set the rules. They fix how the total value of assets under management is computed and how often. They also fix who watches it between computations and what happens on the day it goes over. These articles separate a reporting frequency you can defend from one you assumed. Almost no Annex IV guide mentions them. Regulation (EU) No 231/2013, Art. 2 to 5 · UK assimilated text

The risk lies in how the first row and the fourth interact. It is a control gap rather than a rule. The three-month clock in Article 4 runs from the date the value exceeded the threshold. It does not run from the date you calculated the figure and found out. A firm that computes annually and monitors loosely can meet Article 4 on a clock that started months earlier. When that happens, three obligations arrive together. The first is an authorisation application due within 30 days. The second is a reporting scope that jumps from the three Article 110(1) limbs to the full Article 24 field set. The third is a frequency change with its own transition rules. That sequence is why a sub-threshold manager should implement Article 3 first. It is also the article such managers most often skip.

Your first report after authorisation

New AIFMs consistently get this wrong. You do not wait a full year. You start reporting from the first day of the quarter after you have information to report, through to the end of your first reporting period. ESMA gives a worked example. An AIFM subject to half-yearly reporting that has information to report as from 15 February starts reporting information as from 1 April to 30 June. ESMA Guidelines 2014/869, §12

A registered AIFM that is authorised and immediately becomes subject to quarterly reporting follows a second set of rules (Table 8, Case 1). Its first report covers the whole period since its last Article 3(3)(d) return. The quarter in which you receive your licence changes the answer:

• Authorised in Q1: you do not report at the end of Q1. You report at the end of Q2, covering Q1 and Q2.
• Authorised in Q2: you report at the end of Q3, covering Q1 to Q3.
• Authorised in Q3: you report at the end of Q4, covering Q1 to Q4.
• Authorised in Q4: you report on your old (annual) frequency for that year. The new obligation waits. Guidelines §19 and 20

Other transitions follow other cases. A registered AIFM may opt in to authorisation and stay on annual reporting. It then files the Article 24 information at year end, covering the full period since its last return (§26 and §27). Moves between half-yearly and quarterly reporting have their own quarter tables (§21, §24 and §25). Check your case in Tables 8 to 10 before relying on the list above. ESMA Guidelines 2014/869, §17 to 29

Ireland reduces all of that to one table, the clearest statement of the stub rule any regulator publishes. The Central Bank's AIFMD Reporting Date Matrix covers authorised AIFMs, non-EU AIFMs under a private placement regime and registered AIFMs under Article 3(3)(d). It gives the answer by the quarter in which you were authorised, registered or notified. Read across your frequency. The pattern is what matters, and it applies to any year. CBI: AIFMD Reporting Date Matrix

Two points follow from the matrix that no summary of the guidelines states. First, the label describes the cadence you settle into, not the length of your first file. A half-yearly filer authorised in Q1 or Q3 has a first "half-yearly" report covering three months. An annual filer authorised in Q1 has a first "annual" report covering nine. Second, Q4 brings the longest wait at every frequency, and at annual it is extreme. An annual filer authorised in October has a first report covering the whole of the next calendar year. That report is not due until the January after that: roughly fifteen months with no filing, then a full year's file. In that gap, a process built at launch is forgotten, staff turn over, and the data for the early months goes missing. Build the file before the gap, not after it. The matrix also carries the fund-of-funds extension forward as a footnote: the 15 days apply to the first report too.

Nil returns are mandatory. You may have a gap between authorisation and the start of activity, or between an AIF's creation and its first investments. You still file, and you use the designated field to indicate that no information is available. Having nothing to report is not a reason to skip a period: a missing return is a breach, and a nil return is compliance. The flag is a specific data point, and it overrides the rest of the file. In the Irish implementation, you set data point 21 on the AIFM file ("AIFM no reporting flag") or data point 23 on the AIF file to T. You then leave every field after it empty. If you populate anything downstream, the file fails validation. Guidelines §11 · CBI Reporting Guidance for AIFMs

How do umbrellas, feeders and funds of funds report?

How you split a structure into reports is a procedural rule, not a judgement call:

• Umbrella AIFs report per compartment. You report AIF-specific information at the level of each sub-fund or compartment, not for the umbrella as a whole. The FCA reinforces this from the other end: it issues PRNs at compartment or sub-fund level.
• Each feeder AIF files its own report. Feeders are never aggregated with their siblings or with the master. Identify the master the feeder invests into, but do not look through it to its holdings. Report investments made at feeder level, such as derivatives, in full.
• Funds of funds do not look through either. You report the AIF's holdings in the underlying funds, not the underlying funds' portfolios. That is why the 15-day extension exists. It is also why claiming the extension does not excuse you from having the underlying NAVs.
• A master you market nowhere can still owe its own report. This is a scope risk, and it sits awkwardly next to the rule above. You do not look through the master, yet in one case you file on it. Take an offshore master AIF that you manage but market in no member state. Its feeder is in scope, so in some regimes you report that master in its own right. In the UK this is a Handbook rule. FUND 3.4.6AR obliges a full-scope UK AIFM on quarterly reporting to report AIF-level information for each non-UK AIF it manages that is not marketed in the UK. The same applies to a non-UK AIFM marketing a feeder in the UK. The master needs its own PRN, which the FCA assigns on request via [email protected]. In the UK, quarterly status switches this on, so a step up in frequency can add funds to your filing list without any notice. Ireland sets its own scope, with no quarterly condition. The Central Bank asks for a separate AIF file, with its own C-code, for a non-EU master AIF not marketed in the EU. This applies where the master has EU feeders or non-EU feeders marketed in the Union. That does not apply where the master and the feeder have different AIFMs (CBI guidance, point 4). The underlying basis is ESMA's Article 24(5) opinion on collecting information for systemic-risk monitoring (ESMA/2013/1340). Expect the question in any domicile. FUND 3.4.6AR · FCA Annex IV reporting guide, §30

ESMA Guidelines 2014/869, §33 to 36

Which reports are due when a manager changes or a fund closes?

• The AIFM changes mid-period. The outgoing AIFM reports nothing at period end. The incoming AIFM files one report covering the whole period, using data handed over by the predecessor. The same rule applies where an AIFM is merged away. Build the data handover into the transfer, not after it. Guidelines §14
• An AIF is liquidated or merged. File the last report immediately after. ESMA gives "immediately" a firm limit: no later than one month after the end of the quarter in which the AIF was liquidated or put into liquidation. The final report may be empty, turnover-only, or complete, depending on how much was unwound. Where a liquidator takes over, the AIFM reports before handing across. ESMA Q&A, Section III Q7

Annex IV is two linked reports, delivered as ESMA-schema XML. They are separate reports, which is why they can run on different frequencies. How they travel as files depends on the regulator. The Central Bank accepts several AIF returns in one XML file (CBI guidance), and the FCA also accepts online completion:

The AIF-level report is where the work is. Its field groups are set out below in plain terms.

• Identification: AIF name, LEI or ISIN, domicile, inception date, base currency, AIF type (hedge, PE, real estate, fund of funds, other), and reporting-code type (24(1), 24(2), 24(4)). "Inception date" has a defined meaning. It is the date of authorisation where the AIF is pre-authorised, and otherwise the date the AIF was established.
• Investment strategy and breakdowns: the predominant strategy, then the portfolio broken down by instrument type, geographical focus and currency of exposures. Strategy percentages are of NAV and can be negative. The predominant type is the strategy with the highest absolute percentage. Where no strategy exceeds 50%, you use "multi-strategy hedge fund".
• Principal exposures and concentration: the AIF's principal markets, the five main instruments traded, the value of the assets, and its principal exposures and most important concentrations. For counterparties, you give the BIC and LEI of the five biggest, or the name only where a counterparty has neither.
• Risk profile: market risk (net equity, interest-rate and FX deltas, DV01, CS01), counterparty risk, and the liquidity profile. The liquidity profile covers portfolio and investor liquidity buckets, redemption terms, gates and side pockets. The group also holds operational and other risk, and the results of stress tests. You allocate investor liquidity by the shortest period in which each investor may withdraw. Illiquid assets with indeterminate future liquidity go conservatively into the longest bucket.
• Leverage: leverage calculated under both the gross method and the commitment method, plus the sources of borrowing. Report each method; they are separate mandatory figures for a leveraged AIF.

ESMA AIFMD Q&A, Section III · ESMA Guidelines 2014/869 · schema: ESMA AIFMD reporting IT technical guidance

What does a registered (sub-threshold) AIFM file? The same template, three limbs of it

Every guide says "a lighter set of fields", and almost none says which fields. One article answers it, and the drafting is what matters. Article 110(1) of the Level 2 Regulation refers to the second subparagraph of Article 24(1) and to point (d) of Article 3(3) in the same sentence. It then lists three items. Those three limbs are the whole of the Article 3 content obligation.

• (a) the main instruments in which it is trading, including a breakdown of financial instruments and other assets. This limb also covers the AIF's investment strategies, with their geographical and sectoral investment focus.
• (b) the markets of which it is a member or where it actively trades.
• (c) the diversification of the AIF's portfolio, "including, but not limited to, its principal exposures and most important concentrations".

What sits outside those limbs is the more useful half of the answer. The line is structural, not a field-by-field judgement. Article 110(2) carries the special-arrangements percentage and any new liquidity arrangements. It also carries the risk-management systems and the current risk profile (market and liquidity). It adds the main asset categories with their short and long market values, turnover and performance, and the stress-test results. That paragraph opens "For each of the EU AIFs they manage and for each of the AIFs they market in the Union … in accordance with Article 24(2)". It is the authorised manager's paragraph, and a registered AIFM is not in it. Nor is a registered AIFM in the substantially-levered block. Article 110(5) attaches the Article 24(4) information to paragraph 2. A manager outside paragraph 2 is therefore outside the extra questions, whatever its funds' gearing. Two practical consequences follow. Regulation (EU) No 231/2013, Art. 110(1), (2), (5) and (6)

• It is not a different form. Article 110(6) applies the Annex IV pro-forma template to paragraphs 1, 2 and 5 alike. A registered AIFM files the same template as everyone else, with fewer fields populated. The field-state discipline described below therefore matters just as much to it. Leaving a field blank and being forbidden from populating it are still two different things. Article 5(3) says the same from the registration side. It provides that the Article 110(1) information follows "the pro-forma reporting template as set out in the Annex IV".
• It is still two files, not one. The guidelines' own decision diagram for a registered AIFM reads "Annual AIFM and AIF minimum reporting obligation (3(3)(d) contents)". That means a manager report and a per-AIF report, both at the minimum content. Registration reduces the depth of each file, not the number of files. Guidelines, Annex I §3

The one-month submission deadline and the fund-of-funds 15-day extension sit in that same paragraph 1, so they apply to the Article 3 filer too. Watch what happens when you cross the line in either direction. If you step down from authorised to registered, you report only the Article 3(3)(d) information. You do so in one report covering the full period since your last filing (Guidelines §22, Table 8 Case 10). If you step up by opting in to full authorisation, the scope jumps to the whole Article 24 field set while your frequency stays annual (§26 and §27). Scope and frequency move independently. A sub-threshold manager that budgets for its first full return by counting filings has budgeted on the wrong measure.

Which currency does each file use?

This is a common first-filing error, and validation rejects it outright. The manager report and the fund report use different currencies. Neither defaults to your reporting entity's home currency.

• The AIFM report is always in euro. You report the value of assets under management for all AIFs managed in EUR, whatever currency the funds use. You convert at the European Central Bank rate. Where the ECB publishes no rate for a currency, you report the rate you used. The figure is taken as of the last business day of the reporting period, the same date rule as everything else. Only where every AIF the manager runs shares one single non-euro base currency do you also add the base-currency value. ESMA Guidelines 2014/869, §51
• The AIF report is in the fund's base currency. Monetary values in the fund-level file use that AIF's base currency. That includes the currency-exposure block, where you give long and short values at AIF level in base currency. You identify any currency outside the template's list by its code. Guidelines §106
• The FX-rate fields are conditional, and that is how they fail. The exchange-rate fields are mandatory only where the base currency is not euro. Where it is euro, the FCA's instruction on the UK equivalents (AIF002 Q24 and Q31) is to enter 1 or make no entry at all. Enter anything else and you hit the conditional-field failure described below. The ESMA rules are stricter. In Luxembourg, the FX rate and rate-type fields are forbidden for a euro base currency, so a 1 fails (CSSF Technical Guidance, CAF-030 and CAF-031). FCA Annex IV Q&A, Q36 & Q38

When does the Article 24(4) block apply?

The extra Article 24(4) questions (296 to 301 in the consolidated template) are not for everyone. Only AIFMs managing AIFs that employ leverage on a substantial basis answer them. The phrase has an arithmetic definition: exposure under the commitment method exceeds three times NAV. ESMA tightened how you test it. You compare the average daily commitment-method exposure over the reporting period with the average daily NAV. A point-in-time snapshot at period end is not the test. If you calculate exposure less often than daily, the fund is substantially leveraged where exposure exceeds three times NAV at least once in the reporting period. A fund that gears up mid-quarter and unwinds before the reference date can still be substantially leveraged for reporting purposes. UK filers should note that this whole test is proposed for deletion. FRAME would drop both leverage metrics and the substantially-levered trigger with them. Until the FCA's final rules arrive, the test remains law, so keep running it. Art. 111 · ESMA Q&A, Section III Q18 & Q31

Which validation failures cause a rejection?

Rejections are almost never about the numbers. They are schema or format failures, caught before anyone reads the file. It helps to know the template's three field states. A mandatory field is reported by everyone. An optional field is reported if you have the data. A conditional field depends on a flag elsewhere. Answer the flag "yes" and the dependent fields become compulsory. Answer "no" and they must be left empty. Most rejections that look inexplicable are a conditional pair out of step. ESMA Q&A, Section III Q21

The two codes in the second row deserve a closer look, because first-time filers lose returns in the gap between them. They are not interchangeable and they do not share a scale. A full-scope AIFM with a quarterly obligation answers 5 for its registration status. A leveraged EU AIF it manages answers 29, not 5, for that fund's own reporting code. A below-threshold non-UK AIFM marketing under a private placement regime happens to answer 1 in both fields, which is why the two get conflated. "Authorised" is the wrong attribute to sort on. A small authorised AIFM is authorised, but it answers 1 with the registered managers, not 2 to 5 with the full-scope ones. The FCA publishes the complete mapping as reference tables, with worked examples. The tables run from manager category to registration status, to AIF reporting code, to filing content. FCA, Important information for AIFMD Annex IV transparency reporters, Q1 and annex 2. The field identifiers above are the FCA's. The EU schema uses the same two-field structure but numbers the fields differently.

Validation runs in layers. First comes the ESMA XSD schema check. Next come the ESMA business-rule checks: cross-field consistency, percentages summing and conditional logic. Last come any NCA-specific rules your regulator's portal adds. Passing the schema is necessary but not sufficient. A file can be well-formed XML and still fail a business rule.

Where is the business-rule catalogue published?

The middle layer is published in full, though vendor guides rarely mention it. Each rule has a reference. CAF- codes govern the AIF file and CAM- codes govern the manager file. NCAs publish the catalogue. The Central Bank of Ireland publishes it as a spreadsheet. It holds 162 distinct AIF-level rules, from CAF-002 to CAF-219, and 21 manager-level rules, from CAM-002 to CAM-025. Each comes with its error message, the field it attaches to and the exact control applied. BaFin publishes the same two catalogues as annexes to its § 35 KAGB guidance notice, dated 5 March 2015. The published copies therefore differ in date, and the date matters. Revision 6 became applicable in November 2023. A catalogue dated before then predates the family from CAF-201 to 219 described below. Check the date on your copy before you build a control against it. CBI: AIFMD reporting, list of CAF and CAM errors · BaFin: AIF error codes (Anlage 1) · BaFin: AIFM error codes (Anlage 2).

Take two structural points from the catalogue before any individual rule. First, not every failure rejects the file. The rules are graded as content error, warning, notification, or ungraded. On the CBI's list, 153 of the 162 AIF rules are content errors and 8 are warnings. On the manager side, 17 of 21 are content errors and 2 are notifications. A warning does not stop the filing. Your regulator can see it, though, and you cannot unless you run the rules yourself first. Second, the catalogue exposes a fourth field state that the template documentation does not name. Alongside mandatory, optional and conditional, there is forbidden. A forbidden field must be absent: not near-blank, not zero, not "N/A". A large share of the rules take exactly this form. That is why the instinct to fill everything in is the most reliable way to fail.

The manager file has one arithmetic check worth knowing. It is graded as a notification rather than an error, so it passes without stopping anything. Your total AuM in base currency must equal your total AuM in euro multiplied by the FX rate you reported (CAM-016). A failure will not stop the filing, but the figure will still be wrong.

The practical use of all this is not to memorise codes. It is to run the catalogue against your file before the portal does. The rules are published and apply to everyone. Deadline day is the worst time to meet CAF-201 for the first time.

There is a fourth layer behind the portal that most filers never see. Your NCA is a relay, not the destination. It validates and accepts the file, then forwards it to ESMA, and ESMA can refuse what your regulator took. The submission process makes this explicit at both ends of the EU. Luxembourg returns up to three files for a single submission. The first is an acknowledgement of receipt. The second is the CSSF's own feedback after it analyses the content. The third, a distinct file type, carries ESMA's refusal back to you after the CSSF has already accepted the file. The Netherlands shows the same sequence through status. The AFM validates first and forwards second, so a report showing "Submitted" is not yet accepted. An ESMA rejection arrives as a new open obligation. The consequence is the same everywhere: acceptance by your regulator is an interim state. Do not close the reporting period on it. Do not schedule leave for the person who can fix the file in the week after the deadline. CSSF AIFM Reporting Technical Guidance

The production schema is revision 6 (XSD version 1.2), applicable since 22 November 2023. The reference period for first reporting under it was Y1/H2/Q4/X2 2023. Revision 6 tightened validation, making more fields mandatory or subject to stricter rules. A file built against an older revision therefore fails on fields that used to pass. This is the ESMA-wide baseline, not a national variant. National guidance points at the same revision: the CBI's mandated header names AIFMD_DATAIF_V1.2.xsd and AIFMD_DATMAN_V1.2.xsd. ESMA AIFMD reporting IT technical guidance (rev 6)

How do you correct a return you have already filed?

Every regime on this page lets you fix a filed return. Every one of them rejects the fix if you treat it as a fresh submission. The mechanism is a filing type inside the file, not a button on the portal:

• INIT once, AMND after that. The first clean file for a given report type, period type, period year and manager code is INIT. Send a second INIT for the same combination and the regulator refuses the whole report. It does not merge or duplicate it. Every resubmission for a period you have already filed must carry AMND. Luxembourg and the Netherlands both reject this under their own error codes, which shows it is a template-level rule and not a national one.
• An amendment resends the whole record. A correction is not a delta. When you correct a data record you sent before, you send the complete record again. An export that carries only the changed fields will be rejected.
• Cancelling is a separate action, with its own flag. A cancellation is its own record type and carries a cancellation flag. It only works against a report the regulator already holds. Cancel a report it has no record of and you get an error, not a silent no-op. In practice, amend to correct, and cancel only to withdraw a filing that should never have existed. CSSF AIFM Reporting Technical Guidance · AFM portal manual
• Corrections have a deadline too. The UK puts a number on it. Annex IV needs no separate resubmission request, unlike other returns. The FCA still expects firms to use the amendment function sparingly. It expects amended data that is complete, accurate and final no later than one month after the reporting deadline, which is two months after the reference date. Treat that as the outer edge of the correction window, not as a second deadline to plan around. FCA Annex IV Q&A, Q31
• Ireland adds a lock. Once a return is signed off, you cannot amend it until the Central Bank releases the lock. The correction path in Dublin therefore starts with a request, not an upload. Allow for the turnaround.

Same report, different portal. The portal, format and local requirements by regulator:

If you file under a private placement regime, add a regulator per country

Jersey and Guernsey funds are outside the AIFMD Annex IV regime itself. A Channel Islands manager marketing into the EU or UK under NPPR still files Annex IV to each host NCA where it markets. A Jersey manager selling into Germany and the Netherlands therefore files to BaFin and the AFM. Each has its own portal, its own account-opening lead time and its own local validation. The template comes from Brussels, but each submission process is national and changes on its own timetable. Three common destinations:

The pattern across all three is the same, and it is the one NPPR filers most often miss. The account takes longest, not the file. Portal registration and procedure authorisation are prerequisites, and Germany adds a second approval step. Their lead times run to weeks, and you cannot start any of them on deadline day. The deadline dates for all five domiciles' own periodic obligations sit in the 2026 regulatory calendar. The sub-threshold and NPPR routes are mapped in sub-threshold AIFM regimes by jurisdiction.

Does your home regulator want a copy? Jersey does, Guernsey does not

The two Channel Islands domiciles diverge on one point. Compliance costs almost nothing, but the duty is easy to miss, because it is not in the Directive at all. It sits in the local code:

• Jersey: file it twice. A Jersey AIFM that files Annex IV with a UK or EEA regulator must send the JFSC a copy of that same reporting. It does so on the same frequency it files with the host state, to [email protected]. No filing fees are payable to the JFSC for it. Where the identical report goes to several EEA states or the UK, one copy to the JFSC is enough. That copy must carry written confirmation of where the reporting was filed. Where a Jersey AIF has a non-Jersey AIFM, the copy is only required on the JFSC's request. The obligation's base is the Alternative Investment Funds Code of Practice, and the FAQ is its operational statement. JFSC: AIFMD FAQs
• Guernsey: file it once. The GFSC states that the detailed Article 42 reporting goes to the EEA member state's regulatory authority and not to the Commission. What the GFSC does want is the marketing notification. It must be told within 14 calendar days of marketing starting. Notify the fact locally; report the detail to the host. GFSC: Guernsey's AIFMD regime

Jersey's own framework changed this year, in the same direction as everything else on this page. On 16 April 2026 the JFSC split its AIF Code of Practice in two. A new EU/EEA regime code transposes AIFMD II (Directive (EU) 2024/927) alongside the Level 1 and Level 2 texts. From that date, the pre-existing code applies only to the UK-focused regime. The JFSC published both on 8 April 2026. Jersey has recognised, from the reporting side, the same divergence this page describes: one rulebook could no longer serve both regulators. "Channel Islands manager, EU and UK" is now two compliance positions, not one. Jersey's private-placement route into the EU is itself unaffected. JFSC: AIF Code of Practice, EU/EEA regime · JFSC: AIF Code of Practice, UK regime

• Regulatory AuM is not NAV. The AuM that sets your frequency is computed under the AIFMD method, with derivatives converted to their underlying equivalent. A fund with a modest NAV that runs derivatives can therefore sit in a higher band than its NAV suggests. Compute AuM the AIFMD way before you assume your frequency.
• Your AIFM return and your AIF returns can run on different cycles. Article 110(3) classifies the manager and individual funds separately. The CBI says so explicitly: "AIFMs may need to report their own data at a different frequency to the AIFs under their management". One calendar entry for "Annex IV" is not enough.
• The schedule the portal shows you is not your obligation. The Central Bank and the FCA both put frequency determination on the manager. The FCA goes further. Where the schedule in your account disagrees with the frequency you have determined, you file on your frequency. You then use the change-of-frequency code in the report to correct the schedule. A system that says "half-yearly" is no defence for having filed half-yearly.
• Do not wait a year, except in the one case where you wait fifteen months. File the stub period one month after your first period end, not twelve months on. Note the Q4-authorisation exception that keeps you on your old frequency. Its mirror image is the risk. An annual filer authorised in Q4 has no report at all until January of the year after next, and then owes a full calendar year. The process is most likely to be forgotten in the longest gap in the regime.
• "Left blank" and "forbidden" are different, and one of them fails. A conditional flag answered "no" does more than make its dependent fields optional. It makes them forbidden, so entering "0", "none" or "N/A" causes a rejection. The standard case is a closed-ended fund that fills in its redemption terms as "none".
• File the nil return only when there is nothing to report, and file it empty. A gap before activity starts, or before a new fund's first investments, is still a reporting period. Where you have no information to report, set the no-reporting flag and leave every later field blank, or validation fails (Guidelines §11). No new deployment is not the same as nothing to report. A fund that still holds cash or investments reports them. A period with no trades reports turnover of "0" under the code OTH_OTH_OTH (ESMA Q&A, Section III Q25).
• Two files, two currencies. The manager report goes in euro at the ECB rate, whatever currency your funds use. The fund report goes in that fund's base currency. The FX-rate fields apply only where the base currency is not euro. Where it is euro, the FCA accepts 1 or no entry on its own fields. Under the ESMA and CSSF rules the fields must be absent (CAF-030, CAF-031).
• With a mixed book, the fund-of-funds 15 days do not delay the manager report. If you manage both ordinary AIFs and funds of funds and take the extension, you file the AIFM report twice. The first goes in at one month for everything else. The second is an amended report carrying the fund-of-funds figures. The extension adds work rather than saving it.
• A master you market nowhere may still need its own report and its own identifier. In the UK, quarterly status brings in offshore masters of in-scope feeders. In Ireland, the master needs its own file where it shares an AIFM with the feeder. You must request the identifier for that master from the regulator. Nobody issues it because you filed.
• Never send a second INIT. Once a period has been accepted, every further file for it is an amendment, carrying the whole record again. Resubmitting the fixed file as new causes a rejection.
• Register as a sender before you have a file to send. In Luxembourg, the regulator's register must record the link between the submitting entity and the manager first. If an administrator files for you, you must declare that. In the UK, nothing is available until the fund and firm identifiers are issued. Neither step can be done in the same week.
• Report both leverage methods, every time. Gross and commitment are separate mandatory figures for a leveraged AIF. Omitting one causes a conditional-field rejection. Test "substantial" leverage on average daily figures, not the period-end snapshot. The UK proposes to stop asking for either figure, but not yet, and not for your next return.
• The reference date moves. Under the ESMA guidelines it is the last business day, not the calendar quarter-end. Re-derive it each period, and keep the TARGET date even if you used the previous day's data. The Central Bank's portal instead takes the calendar quarter-end.
• Tell the regulator about the fund before you report on it, and allow for the step you do not control. New AIF, new compartment, changed manager and fund relationship: notify first. Portals that cross-check their own register will simply refuse the return. The business rules also check your codes against ESMA's register of authorised entities, which your NCA populates by notification. The return can therefore fail on an entity your own regulator has already authorised. Neither you nor your regulator controls the timing of that step, and you find out on deadline day.
• Check whether your home regulator wants a copy. Filing to the host NCA can be only half the job. A Jersey AIFM owes the JFSC the same report on the same frequency. A Guernsey AIFM owes the GFSC only a marketing notification. The Directive does not say this; the local code does. Establish it before your first period end, not after.
• Uploading is not filing. Every portal reviewed on this page needs a second, explicit step. Dublin requires sign-off, London requires submission from the reporting schedule, and Amsterdam requires a separate Submit click. A file left validated but unsubmitted is a missed return.
• "Completed" is not permanent. ESMA runs a Data Quality Engagement Framework, which periodically re-examines filings already marked complete. A return that passed can be reopened as a re-report months later. The AFM portal flags these with a DQEF marker on the sequence number. Keep the source data and the exact file you filed, not just the confirmation.
• Not every reporting duty is periodic any more. If you run an open-ended AIF, an LMT activation or deactivation is notifiable in its own right. Suspension and out-of-the-ordinary tool use are notified without delay, and a side pocket in advance. The notification follows a different procedure from your Annex IV file. A process built entirely around period ends has no place for it.
• Validate before you submit. Run the file through the ESMA XSD and the business-rule set locally. The portal will reject on the same rules, but on deadline day, at the worst possible time.

Member States had to apply AIFMD II (Directive (EU) 2024/927) from 16 April 2026. Its transposition article, however, carves out the supervisory-reporting overhaul. The measures transposing Article 1(12), which rewrites AIFMD Article 24, apply only from 16 April 2027. The same applies to Article 2(7), which inserts the new UCITS Article 20a. The current template does not change in 2026. The changes after that are set out below. Directive (EU) 2024/927, Art. 3(1) · CSSF Circular 25/901

You do not have to take that carve-out on trust. Two of the domiciles on this page have already written it into national law at article level. To know what applies to you on 17 April 2027, read those texts rather than the Directive. Ireland's transposition, S.I. No. 181 of 2026, came into operation on 1 May 2026, two weeks after the EU deadline. Its reporting provision, Regulation 14, is held back to 16 April 2027. Luxembourg's Law of 3 March 2026 made the same split through its Article 57. It deferred two reporting articles while the rest took effect on 16 April 2026. The split and the date are the same, but the statutory provisions differ. That matters if you cite an authority to your own committee. S.I. 181/2026 · Legilux, Mémorial A 115

The detail below comes from the Level 1 text itself: Article 1(12) of the amending Directive. It replaces Article 24(1), replaces points (c) and (d) of Article 24(2) and adds a new point (f). Points (a) and (b) are untouched. They cover special arrangements for illiquid assets and new liquidity-management arrangements. Read the original rather than a summary, because the delegation block is much longer than most coverage suggests.

• Full portfolio coverage: the word "principal" comes out. Amended Article 24(1) has the AIFM report on "the instruments in which it is trading" and on "markets of which it is a member or where it actively trades". It must also report "on the exposures and assets of each AIF". No qualifier narrows that to the principal ones or the top five. The data must also carry "the identifiers that are necessary to connect" it to other supervisory or publicly available data sources. Identifier coverage therefore becomes a reporting requirement, not an option.
• Delegation transparency: eight sub-points, not one field. New Article 24(2)(d) lists what you file.
  • (i) each delegate's name, domicile and close links. It also covers whether the delegate is an authorised or regulated entity for asset-management purposes, its supervisory authority and its identifiers.
  • (ii) the FTEs you employ to perform day-to-day portfolio or risk management.
  • (iii) a list and description of the delegated activities.
  • (iv) where portfolio management is delegated, the amount and percentage of the AIF's assets under that delegation.
  • (v) the FTEs you employ to monitor the delegation.
  • (vi) the number and dates of your periodic due-diligence reviews and a list of the issues they identified. Where relevant, it also covers the measures adopted and the date by which those measures are to be implemented.
  • (vii) where sub-delegation arrangements are in place, the information in points (i), (iii) and (iv) for the sub-delegates and the sub-delegated portfolio and risk management activities.
  • (viii) the start and expiry dates of every delegation and sub-delegation.
  Point (vi) deserves the most thought. Your own oversight findings and your own remediation dates become a supervisory return.
• Where the fund is actually marketed. Point (f) is wholly new. It requires "the list of Member States in which the units or shares of the AIF are actually marketed". The marketing counts if it is "by the AIFM or by a distributor which is acting on behalf of that AIFM". Note both halves. The states where the fund is actually marketed are not the same set as the states where you hold an Article 32 notification. The distributor limb also means part of the answer sits with third parties. If your distribution agreements oblige no one to tell you where units were placed, you need a contract change, not a reporting change.
• Leverage moves into the risk-profile point. Amended 24(2)(c) states that the current risk profile includes market, liquidity, counterparty and other risks, "including operational risk, and the total amount of leverage employed by the AIF". Leverage therefore sits inside the risk block rather than beside it. The separate Article 110 frequency test and the Article 111 substantially-levered trigger are Level 2, and this article does not touch them.
• One EU-standard XML. A single ESMA-coordinated schema replaces today's national variations. The current regime never fully achieved that harmonisation. The legal basis is new Article 24(5b). It mandates implementing standards on "the format and data standards" for the reports, on the connecting identifiers, and on the methods and arrangements for submitting them. ESMA has since set ISO 20022 as the format direction (below).
• UCITS reporting arrives too, in almost the same words. AIFMD II inserts Article 20a into the UCITS Directive. It reads as the AIFMD article with the nouns changed. It has the same full-portfolio limb, the same eight-point delegation block and the same actually-marketed list. One difference matters if you run both. At Article 20a(2)(a), the UCITS file carries "the arrangements for managing the liquidity of the UCITS, including the current selection of liquidity management tools, and any activation or deactivation thereof". A UCITS therefore has both. It notifies events under amended UCITS Article 84(3): suspension, out-of-the-ordinary use of tools 2 to 8, and side pockets in advance. From 2027 it also carries LMT information in the periodic report. An AIF notifies the same events under Article 16(2d). The dates differ. The UCITS Article 20a report applies from 16 April 2027, alongside the rewritten AIFMD Article 24. Member States had to apply the event notifications from 16 April 2026 (Directive (EU) 2024/927, Art. 2(13) and Art. 3(1)). Budget for two build-outs, not one.

Two points in the same article are worth acting on now, before the standards arrive. First, the delegation list is a ceiling, not a starting point. Article 24(5a) tells ESMA to specify the "appropriate level of standardisation" of the point (d) information. It then expressly forbids ESMA from introducing reporting obligations in addition to those in point (d). The eight sub-points above are therefore the whole of the delegation requirement, whatever the RTS says about format. Data-sourcing work can start today against Level 1, without waiting for the template. Second, there is a new escalation route. Amended Article 24(5) lets ESMA, after consulting the ESRB, ask NCAs to impose additional reporting requirements in exceptional circumstances. The condition is that the stability and integrity of the financial system need them. It is a Union-level version of the NCA's own power under Article 110 to ask for more.

What will the replacement template look like, and when will it arrive?

Until May 2026, the shape of the post-AIFMD II file was guesswork. That has changed. Under Article 69a of AIFMD and Article 20b of the UCITS Directive, ESMA owed the Commission a report on an integrated reporting system for funds by 16 April 2026. It delivered the report on 4 May 2026. The report is the closest available blueprint for what replaces Annex IV, and four points in it change how you should plan. ESMA Final Report on the integrated collection of funds' data (ESMA12-2121844265-5150, 4 May 2026)

The timing risk is larger than most coverage suggests. The obligation date and the template date are different, and they are now years apart. The amended Article 24 applies from 16 April 2027. ESMA, however, is only mandated to deliver draft RTS and ITS by that same date. The Commission then has to adopt them, and industry then needs an implementation period. ESMA states its own timetable plainly in the final report. A consultation paper on the standards follows later in 2026. IT-system development starts in 2027, subject to funding. Go-live of the new reporting is expected in H1 2029 at the earliest. The wider integration of MMFR and ECB statistical reporting (Phase 2) follows "a few additional years" after that. ESMA also states that existing templates and instructions remain in force and continue to be applied until superseded. In the interim, the amended Article 24 is law and you still file something very like today's file.

Read this before you buy anything. A roadmap that promises a firm 2027 switch-on for a new Annex IV template is a forecast that ESMA's own report does not support. 2026 and 2027 are business as usual on the current template. The real work in that window is data sourcing, not filing. Three field families are almost certainly missing from your reporting warehouse today. The first is delegation detail, down to your own due-diligence findings and remediation dates. The second is full-portfolio granularity with connecting identifiers. The third is the list of Member States where your distributors actually placed units. All three take longer to source than to file. The third may need a contract amendment before you can source it at all. The AIFMD II timeline as a whole is tracked on the AIFMD II implementation tracker.

What is FRAME, the UK track that retires AIF001 and AIF002?

The UK is not transposing AIFMD II, and on 14 July 2026 it stopped waiting for it. HM Treasury published a draft statutory instrument rewriting the legal framework of the UK AIFM regime. The FCA published three consultations alongside it. CP26/28 covers the regime itself. CP26/26 "Fund Reporting for Asset Management Entities" (FRAME) covers what replaces the reporting. FRAME is the one that matters here. It removes AIF001 outright, replaces AIF002, and takes the UK off the Annex IV template this page describes.

The response deadlines moved on 27 August 2026, and they no longer line up:

• FRAME now closes 22 October 2026, extended from 22 September.
• CP26/28's consultation chapters and its prudential discussion chapter close the same day.
• CP26/28's other discussion chapters close first, on 18 September 2026.
• HM Treasury's technical comments on the draft statutory instrument are still due 14 October 2026. The FCA's extension did not move them.

That is four dates across two authorities, and only the FCA's moved. If you are responding to the package rather than one paper, diary them separately. HM Treasury: draft SI and policy note FCA CP26/26 (FRAME) · CP26/26 full text (PDF) · FCA CP26/28

These are proposals, not rules. The design choices are still specific enough to plan against, and several of them reverse the logic the rest of this page follows.

The same package proposes to decommission FSA042 and the DISC 3.5.1R product-summary filing (§7.2 to 7.4). Closed-ended investment companies that are AIFs would drop to annual reporting (§7.8). The timetable runs as follows. Prototype forms arrive by the end of 2026. A policy statement with final rules follows in H1 2027, and the complete regime in 2028. The FCA is also explicitly considering an iterative route. That route would bring in essential reporting for sub-£500m funds before the end of 2027 (§8.13).

What this means if you file in both places. The two regimes now diverge on the two things a reporting build depends on: the unit that sets your obligation and the format of the file. ESMA recommends that the EU move to a modular ISO 20022 file on a monthly base frequency, sized by fund characteristics, not before H1 2029. The UK is moving to a domestic form sized by fund NAV, on lags of 30 to 120 days, from 2027 or 2028. Anything you build in that window should treat "which regulator" as a core dimension, not just a filing address. Neither destination is in final rules yet. In the meantime nothing has actually changed. You file Annex IV, on Article 110 frequencies, into RegData, exactly as before.

One duty is not Annex IV and is not periodic. It is often missed, because it came from a different provision and goes to a different filing address. Member States had to apply it from 16 April 2026, though national commencement can differ (Ireland: 1 May 2026). An AIFM managing an open-ended AIF must notify its regulator of certain decisions on a liquidity management tool. It notifies without delay when it suspends dealing or uses a point 2 to 8 tool outside the ordinary course of business. It notifies before it activates or deactivates a side pocket. An LMT is one of the suspension, gate, notice-period, swing-pricing, redemption-fee and side-pocket measures a fund uses when redemptions exceed what it can sell. The duty belongs on this page for two reasons. It is the event-based reporting the horizon section describes, arriving years ahead of the template that was meant to carry it. And the notification does not travel through your Annex IV channel. Consolidated AIFMD, Art. 16

• Select two tools before anything happens. An AIFM managing an open-ended AIF selects at least two appropriate tools from Annex V points 2 to 8. It communicates its activation and deactivation policies for them to its regulator. The single exception is an AIF qualifying as a money market fund under Regulation (EU) 2017/1131, which may select one (Art. 16(2b)). Ireland adds guidance on which two. Under the AIF Rulebook, the fund ensures its AIFM considers, where appropriate, selecting at least one quantitative-based tool and at least one anti-dilution tool. The quantitative tools are the redemption gate, extension of notice period and redemption in kind. The anti-dilution tools are the redemption fee, swing pricing, dual pricing and anti-dilution levy. That guidance covers the composition of the pair, not just the count. The Rulebook also requires the fund's governing documents to disclose the selected tools and the terms on which each is activated and deactivated. A selection that never reached the constitutional documents is not a selection. CBI AIF Rulebook (July 2026), Liquidity Management Tools
• Then the notification deadline, which runs in two directions depending on the tool. Two cases are notified without delay, after the event. The first is suspension of subscriptions, repurchases and redemptions (Annex V point 1). The second is any tool from points 2 to 8 activated or deactivated in a manner that is not in the ordinary course of business. Side pockets (point 9) reverse the order. Notification is due within a reasonable timeframe before activation or deactivation (Art. 16(2d)). Read that paragraph before you need it. A side pocket decided and executed in the same board meeting has already missed its notification.
• Luxembourg gave the duty its own eDesk procedure, separate from AIFM reporting. The CSSF built a dedicated "Liquidity Management Tool" procedure in two modules. The LMT selection module went live on 23 March 2026. The initial selection and its policies had to reach the CSSF through it by 16 April 2026. The LMT activation module went live on 16 April 2026 for the ongoing notifications. These cover suspensions of subscriptions, repurchases and redemptions, any tool used otherwise than in the ordinary course of business, and side pockets. The CSSF announced the selection module on 18 March 2026 and the activation module in a second communiqué of 10 April 2026. The portal is the same, but the procedure differs. Being a registered Annex IV sender does not give you access to this one. Three points on it are easy to miss:
  • The unit of compliance is the sub-fund, and the duty is already live. The CSSF's reminder is explicit. Existing sub-funds have had to select, activate and deactivate through the procedure since 16 April 2026. New sub-funds must do so from the date they are established. An umbrella that ran the exercise once at fund level has not complied.
  • Since 21 September 2026, the module also takes a notification that is not an LMT at all. A suspension of redemptions only, without a matching suspension of subscriptions, is not a liquidity management tool under the Law of 3 March 2026. Annex V point 1 is the suspension of subscriptions, repurchases and redemptions. The CSSF has nonetheless added the redemption-only case to the activation module. From that date, both its activation and its deactivation are notified there. The legal basis is the national-law provisions for funds under the 2010 Law, specialised investment funds under the 2007 Law and SICARs under the 2004 Law. Only the notification moved. Supporting documentation still reaches the CSSF through the usual communication channels. A control that treats the module as the whole filing will therefore fall short.
  • The module reaches vehicles the Directive duty does not. Two sets sit outside the 2026 Law but inside the module. The first is a Part II 2010-Law fund with no Luxembourg-domiciled authorised AIFM. The second is a 2007-Law or 2004-Law vehicle that is not an AIF or has no Luxembourg authorised AIFM. Both notify through the same module the activation and deactivation of a suspension of subscriptions, repurchases and redemptions. Both also notify there the creation of a previously approved side pocket. The basis is their own sectoral law, not AIFMD II. Being out of scope of the 2026 Law does not answer whether you use the module.
  CSSF communication, 18 March 2026 · CSSF communication, 18 September 2026
• Ireland collects LMT data through a daily return. The Rulebook's express notification covers only suspensions; the statutory triggers still apply.
  • The return. Since December 2024, the Central Bank has collected daily subscription and redemption data through the Daily Investment Funds Return (DIFR). It applies to every Irish-resident non-money-market fund that issues its own shares, units or interests, has a non-zero NAV and is authorised by the Central Bank. An umbrella that only provides services to its sub-funds is excluded (CBI DIFR). In a second phase in August 2025, it extended the return to liquidity-management-tool usage. LMT reporting is triggered by the application of a tool, not its availability. The Bank describes the return as one that "replaces trigger-based liquidity reporting". The revised AIF Rulebook took effect on 5 May 2026. Its LMT sections carry no general LMT notification, only the suspension duty below. The Bank has not said that the daily return replaces the Article 16(2d) notification (see To verify).
  • What survives is the suspension notification. Read in the Rulebook itself, it is tighter than the summaries suggest. The duty sits in the Liquidity Management Tools sub-section of each fund chapter, under the heading Suspensions. Chapter 1 for Retail Investor AIFs, Chapter 2 for QIAIFs and the ELTIF chapter carry the same four paragraphs. The duty applies only to open-ended funds and open-ended funds with limited liquidity.
  • Paragraph 1 splits the trigger in two. Suspension of subscription, repurchase and redemption is one notification. Suspension of NAV calculation is a second. Each is due immediately when activation or deactivation takes effect. Lifting a suspension is therefore as notifiable as imposing one.
  • Paragraph 2 adds an update at the expiry of 21 working days, and at each further 21-working-day period while the suspension continues.
  • Paragraph 3 is the one almost nobody carries in a control. Another member state's regulator may use its Article 46(2)(j) power to require your AIFM to activate or deactivate a suspension. The fund must then inform the Central Bank immediately on becoming aware of the instruction. Someone else's regulator triggers this notification, not your own decision.
  • Paragraph 4 obliges you to keep the Bank informed as the situation develops.
  • Gates and side pockets. The rules alongside are mechanical. An activated redemption gate reduces that dealing day's requests rateably. It carries them forward to each later dealing day until they are satisfied. A side pocket may use physical or accounting segregation, where the governing documents provide for it and unitholders were told in advance. One carve-out prevents a false positive. Retaining redemption proceeds until the underlying fund pays out, where the prospectus provides for it, is expressly not the activation of a redemption gate.
  • The Level 1 duty is unaffected. An Irish AIFM still owes the without-delay notification under Article 16(2d), as transposed by S.I. No. 181 of 2026. Whether the daily return discharges that notification, or a separate notice is still needed, is not settled. Plan for a separate notice until the Bank says otherwise. Know who files the DIFR. It is an Excel return, due by 12 noon T+2 for a daily-dealing fund. Responsibility lies with the fund's directors even where the task is delegated, and the fund administrator usually files it. That is usually not the person who owns Annex IV. DIFR guidance notes
  CBI: Daily Investment Funds Return · CBI AIF Rulebook · S.I. No. 181/2026
• This route does not reach a UK AIFM. The UK is not transposing AIFMD II. The FCA is, however, proposing its own event-based trigger for large hedge funds under FRAME. The idea is the same, by a different route. Note it if you file in both places and are deciding where event-driven filings sit in your controls.

The practical point for whoever owns the Annex IV process: you do not report an LMT activation in next quarter's file. Your calendar needs a trigger for it, not a date. If your reporting controls are all keyed to period ends, this obligation has no place in them. The substantive rules are on the AIFMD II implementation tracker. That page covers which tools count toward the two, the Level 2 detail, and the transitional period for funds constituted before 16 April 2026.

Two Level 2 instruments sit under all of this. Knowing which is which settles most questions about whether a rule applies yet. The characteristics of each tool come from Commission Delegated Regulation (EU) 2026/465. It was adopted on 17 November 2025, published in the Official Journal on 27 February 2026 and applies from 16 April 2026. Regulation (EU) 2026/466 is its UCITS twin. The selection and calibration of the tools come from ESMA's Guidelines on Liquidity Management Tools of UCITS and open-ended AIFs (ESMA34-671404336-1364), published 12 March 2026. Luxembourg applies them through Circular CSSF 26/910 of 15 April 2026. Both carry the same one-year derogation, and it is narrower than it sounds. A fund existing before 16 April 2026 is deemed to comply until 16 April 2027. The sources are Article 10 of the Regulation and paragraph 4 of the Guidelines' scope. Such a fund may opt in early by notifying its competent authority. The derogation does not touch the notification duty in Article 16(2d). That duty is Level 1. Member States had to apply it from 16 April 2026, and national commencement can differ: Ireland's transposition came into operation on 1 May 2026 (above). Inside the grace period, you still tell the regulator when you suspend. Reg. (EU) 2026/465 · ESMA LMT Guidelines · Circular CSSF 26/910