AIFMD II Annex IV: 5 New Mandatory Fields You Must Know
With 21 days to April 16, here's what the ESMA 2025 schema added to your reporting obligations — and exactly what each field needs.
Why Your Schema Version Matters Now
The 2013 ESMA Annex IV schema — still in use at many firms — does not contain these five fields. They were introduced in the 2025 schema update published alongside AIFMD II (Directive 2024/927). The difference is not cosmetic. NCAs are running validation against the new schema from day one of enforcement.
Check your current schema version by looking at the xsi:noNamespaceSchemaLocation attribute in your XML. If it references a 2013 or 2019 schema URL, your pipeline needs updating before April 16. Download the current schema from the ESMA reporting page and regenerate your XML output.
With 21 days to the enforcement date, this is the single highest- impact change you can make today.
The 5 New Mandatory Fields
The following fields were added or expanded by AIFMD II and are mandatory for all in-scope AIFMs from April 16, 2026. Each is described with its schema location, obligation level, and what you actually need to report.
For the first time, AIFMD II introduces EU-wide rules on loan-originating AIFs (Article 9(2a)). This field classifies whether your fund actively originates loans and, if so, under which legal structure.
Boolean flag plus one of: RegisteredCreditInstitution, ProfessionalInvestorOnly, or NonCompliantStructure. NCAs treat 'NonCompliantStructure' as a regulatory trigger — report accurately and resolve the structural issue separately.
AIFMD II formalised five liquidity management tools that AIFMs can use: dilution levies, swing pricing, redemptions gates, redemption committees, and side pockets. This field captures which tools your fund has activated — or confirms none are in use.
One or more of: DILUTION_LEVY, SWING_PRICING, GATES, REDEMPTION_COMMITTEE, SIDE_POCKET. If no tools are used, report NONE. NCAs compare this against your fund documents — inconsistency is a red flag in inspections.
AIFMD II replaced the old leverage ratio threshold bands with a new four-band classification system. The band determines your reporting frequency: the higher the leverage, the more frequent the filing.
Band 1 (< 3x), Band 2 (3x–6x), Band 3 (6x–9x), or Band 4 (> 9x). Report both the Gross and Commitment method values. Band is determined by the higher of the two methods.
AIFMD II expanded reporting on investor concentration. If your fund has investors who individually hold more than 10% of NAV or voting interests, you must now disclose this in Annex IV. This field captures the threshold and the identity category of qualifying beneficial owners.
Number of beneficial owners exceeding 10% threshold, aggregate concentration percentage, and investor category (Professional, Semi-Professional, or Retail). Updated each reporting period.
AIFMD II introduced explicit substance requirements for delegates, building on ESMA's 2013 letterbox entity guidance. This field captures whether delegates meet the substance test and is one of the most scrutinised additions by NCAs.
For each delegate: delegate name, jurisdiction, functions delegated, number of relevant FTEs, and a YES/NO substance adequacy flag. Be precise — NCAs cross-reference this against your delegation contracts and HR records.
Field-by-Field Validation Pitfalls
Based on ESMA's published validation rules and NCA-specific checks, here are the most common reasons each field fails:
- Loan Origination Classification: Many managers report YES to loan origination but don't populate the sub-field for legal structure. Both fields must be present. BaFin validates this against KAGB registration.
- Liquidity Tool Disclosure: The most common error is leaving this field empty rather than reporting NONE. An empty field is not equivalent to NONE — NCAs treat it as a failed validation.
- Leverage Band: CSSF requires both Gross and Commitment values even when the band is determined by one method. AMF additionally requires a narrative explanation in the Qualitative section for Band 3 and Band 4 filings.
- Beneficial Ownership: Threshold is measured at reporting date NAV, not committed capital. Many managers incorrectly use committed capital figures. Update your calculation at each reporting date.
- Delegation Substance: The FTE count must reflect staff directly performing the delegated function, not total headcount. CSSF has rejected filings where a delegate reported 200 FTEs for a function that had 3 dedicated staff.
NCA-Specific Additions
Beyond ESMA's schema, several NCAs add their own required fields or validation rules on top of the five new mandatory fields:
- BaFin (Germany): Requires a KAGB-equivalent classification cross-reference in the Qualitative section. If your fund is also registered under KAGB, the AIFMD II and KAGB classifications must be consistent.
- AMF (France): Adds a ORI-specific annex for liquidity tool activation that must accompany the Annex IV XML. File both — AMF will not process the Annex IV filing without the ORI annex.
- CSSF (Luxembourg): Requires a CSSF-specific Delegation Agreement Reference Number in the substance field. This number is assigned by CSSF upon registration of the delegation arrangement — if you don't have one, apply now.
Browse the NCA Profiles on Caelith for your regulator's specific field requirements.
How to Update Your Pipeline
If you generate Annex IV XML programmatically, the five new fields require additions to your data model, XML template, and validation layer. Here's a practical sequence:
- Update your schema reference: Point your XML generator at the 2025 ESMA XSD. The new fields will appear as required elements in your generated output.
- Map data sources: Loan origination classification comes from your fund legal structure. Liquidity tool disclosure comes from your fund documentation. Leverage band is calculated from your portfolio data. Beneficial ownership requires data from your investor relations or administration system. Delegation substance requires data from your delegate agreements and HR records.
- Add validation rules: At minimum, validate that Loan Origination sub-fields are co-present, that Liquidity Tool is never empty (NONE is valid), and that Leverage Band values are in range.
- Test with NCA sandbox: BaFin, AMF, and CSSF all offer test portals. Submit a dummy filing with all five fields populated before your first real deadline.
Caelith handles all five fields automatically as part of its Annex IV generation pipeline — data mapping, schema compliance, NCA-specific validation, and test portal submission. Try the API demo to see it in action.
Caelith generates AIFMD II-compliant Annex IV XML automatically — all five new mandatory fields included, validated, and mapped to your NCA's specific schema requirements.