What is the AIFMD? — Alternative Investment Fund Managers Directive (EU)
The AIFMD — Directive 2011/61/EU — is the EU rulebook for managers of alternative investment funds: every collective investment undertaking that is not a UCITS. An AIFM (alternative investment fund manager) is the entity responsible for a fund's portfolio management and risk management; the directive regulates that manager, not the fund product itself. An authorised AIFM gets the EU-wide passport to market its funds to professional investors off one home-state authorisation.
The directive's key sorting mechanism is size. Under Article 3(2), a manager with total AuM below €100m including leverage — or below €500m where every portfolio is unleveraged and locked up for five years — is "sub-threshold": it registers with its national regulator instead of seeking full authorisation, and loses the passport in exchange. Full-scope AIFMs carry the whole stack: depositary appointment, valuation rules, delegation limits, remuneration rules and Annex IV supervisory reporting.
The directive was substantially amended by AIFMD II (Directive (EU) 2024/927), whose obligations apply from 16 April 2026 — loan-origination rules, liquidity management tools, delegation notification and revised third-country marketing conditions. The rewritten supervisory reporting follows on 16 April 2027.
The practical gotcha: "we're under the threshold, so AIFMD doesn't apply" is wrong — sub-threshold managers still register, still report annually, and still trip into full scope the moment AuM drifts over the line.