Frequently asked questions

AIFMD, AIFMD II & the manager rules

What is AIFMD, and what does it stand for?

AIFMD is the Alternative Investment Fund Managers Directive (Directive 2011/61/EU) — the EU framework that authorises and supervises the managers of alternative investment funds (hedge, private equity, credit, real-estate and most non-UCITS funds), not the funds themselves. It sets the rules on authorisation, capital, risk and liquidity management, delegation, depositaries, remuneration and transparency reporting. See the AIFMD reference page and the glossary entry.

What is AIFMD II, and is it in force yet?

AIFMD II (Directive (EU) 2024/927) is the review of AIFMD. It entered into force in 2024, and member states must transpose it into national law by 16 April 2026 — that is the date the new obligations start to bite, including the loan-origination regime, mandatory liquidity-management-tool selection, and expanded delegation and reporting rules. Track what applies when, per member state, on the AIFMD II implementation tracker.

Who does AIFMD II apply to?

Broadly the same population as AIFMD — authorised EU AIFMs, and non-EU managers marketing into the EU under the national private placement regimes — plus, for the first time, a dedicated regime for funds that originate loans. Sub-threshold (registered) managers stay outside full authorisation but pick up some new reporting. The tracker breaks the changes down by who is affected.

What is an AIFM, and what is a sub-threshold AIFM?

An AIFM is the legal entity that manages an alternative investment fund — it holds the authorisation and carries the regulatory obligations. A sub-threshold (or "registered") AIFM manages assets below the AIFMD thresholds (€100m with leverage, or €500m unleveraged and closed-ended) and is registered rather than fully authorised — lighter obligations, but no marketing passport. See sub-threshold AIFM, by jurisdiction.

What is AIFMD Annex IV reporting?

Annex IV is the periodic transparency report every AIFM files with its regulator on each fund it manages — covering strategy, exposures, leverage, liquidity and risk. Frequency (annual, half-yearly or quarterly) depends on assets under management and fund type. The practical mechanics, deadlines and common filing traps are in the Annex IV practical guide, and every 2026 deadline is on the calendar.

Jersey, Guernsey, Ireland & Luxembourg

What is a Jersey Private Fund, and are Jersey private funds regulated?

A Jersey Private Fund (JPF) is a lightly-regulated private fund open to no more than 50 offers/holders, authorised by the JFSC usually within 48 hours through a designated service provider. It is regulated — but proportionately: there is a registered manager and a JFSC consent, without the full fund-regulation overlay. See the JPF reference page and the glossary entry.

What is a private investment fund (the Guernsey PIF)?

Guernsey's Private Investment Fund (PIF) is its fast, closely-held private regime — built around a genuine relationship between manager and a limited number of investors, with a licensed manager standing behind it. The 2025 PIF rules are summarised on the Guernsey PIF page and the glossary entry.

What is the Irish ILP?

The Investment Limited Partnership (ILP) is Ireland's partnership vehicle for closed-ended strategies — private equity, private credit and real assets — modernised by the ILP (Amendment) Act 2020 to compete with Luxembourg's limited partnerships. It is a regulated AIF with a GP and an authorised AIFM. See the ILP glossary entry and, for credit strategies, Ireland vs Luxembourg for loan-originating funds.

Is Jersey or Guernsey a tax haven — are they tax-free?

Neither is "tax-free." Jersey and Guernsey operate a 0% standard rate of corporate income tax for most companies (with higher rates for specific sectors such as banking and, in Jersey, large retail and utilities), which is why funds domicile there — but they run economic-substance regimes, are on the relevant transparency and information-exchange frameworks, and levy personal and goods taxes. "Tax haven" is a label, not a legal status; the operative facts are the 0% default rate plus substance requirements.

Fund types & key concepts

What is ELTIF 2.0?

ELTIF 2.0 is the revamped European Long-Term Investment Fund regime (Regulation (EU) 2023/606, applying from January 2024), which widened eligible assets, eased the rules for retail access and softened the diversification and liquidity constraints — turning a little-used label into a workable private-markets-for-retail wrapper. See the ELTIF reference page, the glossary entry, and ELTIF 2.0 vs a Part II UCI.

What is loan origination, and who pays the origination fee?

Loan origination is a fund making loans directly to borrowers rather than buying them on the secondary market — now a regulated activity under AIFMD II, with rules on risk retention, leverage and diversification. The origination fee (a percentage charged when a loan is written) is paid by the borrower, and compensates the lender for underwriting and setting up the facility. For the domicile choice, see Ireland vs Luxembourg for loan-originating funds.

What is NAV error correction (NAV adjustment)?

A NAV error is a mistake in a fund's published net asset value; correction is the process of restating it and compensating whoever lost out — investors or the fund — once the error breaches a materiality threshold (often 0.5% of NAV, but it varies by domicile and fund type). Who bears the cost, and when a regulator must be told, is set out jurisdiction by jurisdiction in the NAV error correction matrix.

The Luxembourg CSSF circulars

What is CSSF Circular 24/856?

CSSF Circular 24/856 is Luxembourg's regime on the protection of investors in the case of NAV calculation errors, breaches of investment rules and other errors — it replaced the long-standing 2002/77 circular and applies from 1 January 2025, tightening the rules on error thresholds, correction, reporting to the CSSF and record-keeping. Read the annotated 24/856.

What is CSSF Circular 25/901?

CSSF Circular 25/901 is a more recent CSSF circular consolidated on this site — see the consolidated 25/901 page for what it covers, what changed, and the primary text.

About this site

Who runs FundRegTracker?

It is run by an experienced fund-services practitioner, powered by a team of AI agents — independent, and not affiliated with any regulator, law firm or fund administrator. More on the why and the method is on the About page.

Where does the data come from?

Every reference page is built from primary sources — the directive, regulation, statute or regulator circular itself — and links straight to them. Fund and registration data comes from public regulator registers and official filings (for example, SEC EDGAR for US registrations). The sourcing standard and coverage are set out under About & methodology.

How often is it updated?

Continuously, and every page shows its own Last verified date so you never have to guess. Changes in the law — amendments, new effective dates, corrections — are logged right on the relevant page's change ledger. If something looks stale, the date will tell you.

Is it free? Is there a paid tier?

The reference pages, calendar, glossary, search and ask-the-law tool are free. Some data tools — such as the personalised, exportable fund calendar — are planned as a paid tier; where that is the case the page says so. There is no paywall on the regulatory reference itself.

How do I report an error or suggest a correction?

Please do — corrections are welcome and substantive ones are logged on the page. Use the contact details on the About page. Flagging the page and the primary source you are relying on gets it fixed fastest.

Is any of this legal advice?

No. FundRegTracker consolidates public regulatory sources for information only — always verify against the linked primary text and take professional advice for your specific situation.

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