AIFMD II Countdown: 28 Days to April 16

Why 28 Days Is Both a Lot and Very Little

Depending on where you are in your compliance journey, 28 days can feel manageable or terrifying. If you have a well-staffed compliance team and a modern reporting infrastructure, you probably just need to validate a few schema updates and you're done. If you're running Annex IV filings through a combination of spreadsheets and hope, April 16 is going to be a difficult day.

The EU transposition process gives member states until April 16 to bring their national law in line with AIFMD II. Once that date passes, NCAs will begin enforcement — and that means your next Annex IV filing will be judged against the new requirements, not the old ones.

For fund managers who have been watching from the sidelines, the grace period is over. Here's a precise, prioritised checklist of what you need to address in the next four weeks.

Week 1 (Days 1–7): Structural Audit

Start with the questions that require legal and structural analysis — because if the answers are wrong, no amount of reporting effort will fix them.

Article 9(2a) of AIFMD II introduced EU-wide rules for loan-originating AIFs for the first time. The rules are not optional — if your fund is in scope and non-compliant, you face regulatory action, not just a filing rejection.

Also in Week 1: identify whether your fund has crossed any of the new reporting threshold bands under AIFMD II. A manager that was below the €100M non-leveraged threshold may now be in a higher reporting frequency band. Check with your NCA's published guidance — several regulators (including BaFin and AMF) have published Q&A documents clarifying the new thresholds.

Week 2 (Days 8–14): Technical and Reporting Infrastructure

With structural questions answered, focus on the technical layer. This is where most teams will find the most work.

ESMA published the updated Annex IV reporting instructions alongside the directive. Key changes include new fields for portfolio composition, leverage calculation methodology (Gross vs Commitment — both now required), and liquidity tool disclosures. If your reporting software hasn't been updated to reflect these changes, contact your vendor immediately.

For teams building their own XML pipelines: the ESMA schema files are available on the ESMA website. Pay particular attention to the Portfolio and QualitativeReporting sections, which have the most new content under AIFMD II.

Week 3 (Days 15–21): Delegation and Substance

Delegation reviews are the compliance task that keeps getting deferred — because they're difficult, sensitive, and involve conversations with third-party delegates. April 16 is close enough that they can't be deferred any longer.

AIFMD II introduced explicit substance requirements for delegates. Your NCA will be looking at whether the entity to which you delegate portfolio management or risk management has:

• Appropriate expertise and resources in the asset class or strategy being managed
• Actual decision-making authority (not just executing instructions)
• Physical presence (staff, offices) proportionate to the functions delegated
• Sufficient independence from the AIFM to avoid conflicts of interest

Compile a delegation map: who delegates what, to whom, in which jurisdiction, and why that delegate was chosen. If your NCA asked tomorrow, could you produce that document within 24 hours? If not, build it now.

Also review your AIFMD II delegation guidelines — ESMA published additional guidance on letterbox entities in 2023, and NCAs are actively applying these principles in registration reviews.

Week 4 (Days 22–28): Final Validation and Submission Dry Run

The final week is for catching what you missed — and it's where teams who've been on top of things can pull ahead.

Run a dry-run submission with your NCA portal if possible. Most NCAs accept test submissions that don't count as official filings. This is the single most valuable thing you can do in the final week. It surfaces portal-specific quirks, authentication issues, and schema validation differences that you won't find by reading documentation.

Specific portal issues to check:

• BaFin: Check your IHV portal access is active and that your LEI is correctly linked to your AIFM registration
• AMF (France): Verify your ORI file format and make sure the new Annex IV fields are mapped correctly in your submission template
• CSSF: Confirm your XML submission passes CSSF-specific validation rules (CSSF applies stricter checks than the ESMA schema in some areas)

Finally, assign a compliance owner for the April 16 date. Someone should be watching for NCA announcements on the day — some regulators publish late technical guidance, and being the last to know is a competitive disadvantage.

NCA-Specific Considerations

AIFMD II transposition is a national process, and NCAs have some discretion in how they implement the rules. Don't assume that what applies in Germany applies in France.

• BaFin (Germany): Germany transposed AIFMD II via the FiMaNoViÄndV and KAMaVer. BaFin has published extensive Q&A on its website. Loan origination AIFs should pay particular attention to the KAGB implications alongside AIFMD II.
• AMF (France): AMF published its AIFMD II transposition in the AMF General Regulation. French AIFMs should confirm their ORI filings include the new liquidity tool disclosures. AMF has also tightened its approach to non-EU AIF marketing under Art. 42.
• CSSF (Luxembourg): Luxembourg's transposition is through the 2013 AIFM Law (as amended). CSSF has been relatively active in providing guidance. Cross-border managers registered in Luxembourg should review their ReportingMemberState obligations carefully.
• CBFA/KMU/FCA (Belgium): Belgium's transposition is still in progress as of March 2026. Belgian AIFMs should monitor the FSMA website for final rules.

For a full country-by-country breakdown, see our AIFMD II Deadlines 2026 post, or browse the NCA Profiles on Caelith for filing-specific details.

The 28-Day Compliance Checklist