AIFMD II Reporting to FCA: Everything You Need to Know
Financial Conduct Authority — United Kingdom
Contact & Filing Portal
- Website
- https://www.fca.org.uk
- Filing Portal
- FCA RegData
- firm.queries@fca.org.uk
- Phone
- +44 20 7066 1000
Transposition Status
Divergent (post-Brexit)The UK retained AIFMD I via the European Union (Withdrawal) Act 2018, now operating as "UK AIFMD." The FCA has proposed its own reforms diverging from AIFMD II, particularly around reporting requirements, leverage limits, and delegation rules. The UK's AIFMD-equivalent framework is evolving independently from EU AIFMD II.
Filing Deadlines
For full-scope UK AIFMs managing leveraged funds or >£1bn AuM
For mid-sized UK AIFMs
For small authorized/registered AIFMs
FCA-Specific Quirks & Deviations
UK-specific Annex IV divergence
FCA's version of Annex IV retains the AIFMD I structure but adds UK-specific fields including FCA fund reference numbers (FRNs), UK investor classification categories, and GBP-denominated reporting thresholds.
RegData submission format
FCA uses its proprietary RegData platform rather than any ESMA-compatible filing system. Data is submitted via structured web forms or XBRL-based upload — XML Annex IV files are not directly accepted.
NPPR regime for EU AIFMs
EU AIFMs marketing in the UK must use the National Private Placement Regime (NPPR) and file additional FCA notifications. This creates a separate reporting stream from the main Annex IV filing.
Senior Managers & Certification Regime (SMCR) overlay
UK AIFMs must also comply with SMCR accountability mapping that ties AIFMD reporting obligations to named senior managers. Filing failures can result in personal regulatory action.
Different leverage calculation approach
FCA retains the gross and commitment methods from AIFMD I without adopting AIFMD II's refined leverage reporting categories. This means dual-calculation if reporting to both FCA and an EU NCA.
No ESMA data sharing
Post-Brexit, FCA does not share Annex IV data with ESMA. AIFMs operating in both the UK and EU must file completely separate reports — no cross-recognition or data sharing arrangements exist.
How Caelith Helps with FCA
- ✓Generates both ESMA Annex IV and FCA RegData-compatible outputs from a single dataset
- ✓Handles dual leverage calculations (EU AIFMD II + UK AIFMD I methods)
- ✓Manages NPPR notification filings for EU AIFMs marketing in the UK
- ✓Maps FCA fund reference numbers (FRNs) alongside LEIs
- ✓Tracks divergent UK vs. EU deadlines and requirements in a unified dashboard
Frequently Asked Questions
Is the UK implementing AIFMD II?▾
Can I file ESMA Annex IV XML with the FCA?▾
Do I need dual reporting for UK and EU operations?▾
What is the NPPR and how does it affect AIFMD reporting?▾
Related Resources
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