AIFMD II Deadlines 2026: Filing Calendar by Country
The April 16, 2026 enforcement date is approaching. Here's exactly what each EU member state expects — and where the gaps are.
What Is AIFMD II and Why Does It Matter?
AIFMD II (Directive 2024/927) is the first major overhaul of the Alternative Investment Fund Managers Directive since its inception in 2011. It introduces expanded reporting obligations, new loan origination rules, enhanced liquidity management tools, and revised delegation requirements.
For fund managers filing Annex IV reports, the impact comes in two waves. April 16, 2026: operational requirements take effect (LMTs, delegation substance, loan origination rules). April 16, 2027: ESMA's new harmonized Annex IV reporting template and technical standards (RTS/ITS) replace the current template with significantly expanded data fields.
The enforcement date is April 16, 2026. But "enforcement" doesn't mean every country is ready. EU directives require transposition into national law, and member states move at very different speeds.
Transposition Status by Country
As of late March 2026, here is the transposition status across the major EU fund domiciles:
| Country | NCA | Status | Date / Notes |
|---|---|---|---|
| 🇱🇺 Luxembourg | CSSF | ✅ Transposed | Bill 8628 adopted Feb 12, published March 9, 2026. In force April 16. |
| 🇩🇪 Germany | BaFin | ✅ Passed | Fondsrisikobegrenzungsgesetz (FRiG) passed Bundestag March 5, 2026 |
| 🇫🇷 France | AMF | ⚠️ Pending | No implementing ordinance published. Amendments to Code monétaire expected. |
| 🇪🇸 Spain | CNMV | ⚠️ Delayed | No draft legislation published. Expected to miss April 2026 deadline. |
| 🇬🇧 United Kingdom | FCA | 🔵 N/A | Not subject to AIFMD II. Own reform agenda (Edinburgh Reforms) |
Luxembourg's Bill 8628 was the first EU transposition, adopted February 12, 2026 and entering force April 16. Germany's Fondsrisikobegrenzungsgesetz (FRiG) passed the Bundestag on March 5, 2026 with CDU/CSU and SPD support — ending months of uncertainty for German KVGs.
France and Spain are the concern. France has not yet published implementing legislation despite the April 16 deadline — amendments to the Code monétaire et financier are expected but outstanding. Spain is furthest behind: no draft legislation published, and CNMV-regulated AIFMs face potential filing ambiguity in Q2 2026.
Filing Frequency: Who Files When?
Your Annex IV filing frequency depends on your AUM and whether your funds use leverage. This doesn't change under AIFMD II — but the content of each filing expands considerably.
| AIFM Type | AUM Threshold | Filing Frequency |
|---|---|---|
| Registered (sub-threshold) | < €100M | Annual |
| Licensed, leveraged funds | > €100M (leveraged) | Quarterly |
| Licensed, unleveraged | > €500M (unleveraged) | Semi-annual |
| Large individual AIF | > €500M NAV (single fund) | Quarterly (fund-level) |
Key point: If you manage a leveraged fund above €100M, you file quarterly. Filing frequency rules apply from April 2026. However, ESMA's new harmonized Annex IV template (RTS/ITS) is due April 16, 2027. Between April 2026 and April 2027, filings continue under the existing template — but you should start preparing your pipeline for the expanded data requirements now.
NCA Submission Deadlines: Not All Equal
ESMA sets minimum deadlines, but each NCA can set stricter ones. Here's what you actually face:
| NCA | Quarterly | Semi-Annual | Annual | Notes |
|---|---|---|---|---|
| BaFin (DE) | T+30 cal. days | T+30 cal. days | T+30 cal. days | Informal 5-business-day grace period |
| CSSF (LU) | T+30 cal. days | T+45 cal. days | T+45 cal. days | Late filings trigger automatic inquiry |
| AMF (FR) | T+30 cal. days | T+30 cal. days | T+30 cal. days | GECO portal maintenance at quarter-end |
| CNMV (ES) | T+45 cal. days | T+45 cal. days | T+60 cal. days | Most generous deadlines in EU |
| FCA (UK) | T+30 bus. days | T+30 bus. days | T+30 bus. days | Business days — ~6 extra days vs EU |
Notice the differences: CSSF gives you 45 calendar days for annual filings while BaFin gives you 30. CNMV is the most lenient at 60 days for annual reports. The FCA counts business days, effectively giving UK-regulated managers nearly a week more than their EU counterparts.
For cross-border managers filing to multiple NCAs, these differences matter. A fund managed from Germany but domiciled in Luxembourg must meet both BaFin and CSSF deadlines — and the stricter one wins.
What Should You Do Now?
With less than two months until the April 16, 2026 enforcement date, here's the practical checklist:
- Audit your current reporting pipeline. Can it handle the new AIFMD II data fields? If you're using Excel macros or manual XML assembly, the answer is almost certainly no.
- Check your NCA's transposition status. If you're CSSF-regulated, you're already under the new rules. If you're BaFin-regulated, prepare for the April deadline.
- Map your filing frequencies. Know whether you file quarterly, semi-annually, or annually — and calculate your first AIFMD II filing date.
- Test with the new schema. ESMA's updated XSD is expected in Q1 2026. Build or update your validation pipeline now.
- Automate. The expanded reporting requirements make manual filing increasingly risky. One missed field, one wrong enumeration, and your report is rejected.
What About the UK?
The UK is not subject to AIFMD II. Post-Brexit, the FCA operates under retained EU law with its own reform agenda. However, UK-based AIFMs marketing funds into the EU still need AIFMD II compliance for their EU-facing activities.
Additionally, the FCA still uses ESMA XSD Revision 5 (not Revision 6), meaning UK-filed Annex IV reports need a different XML format than EU-filed reports. If you manage funds across both jurisdictions, your pipeline needs to support both schema versions.
Don't Get Caught Off Guard
Caelith's compliance copilot knows every NCA deadline and filing quirk. Ask it about your specific situation.