AIFMD II Annex IV: What Changes for Your Next Filing

Two Dates, Two Sets of Obligations

AIFMD II creates a split timeline that catches many managers off guard:

• April 16, 2026 — Member state transposition deadline. Operational requirements take effect: LMT selection, delegation substance, loan origination rules, leverage limits. These apply even though the Annex IV template hasn’t changed yet.
• April 16, 2027 — New ESMA harmonized Annex IV reporting template takes effect. ESMA must deliver RTS and ITS specifying standardized reporting templates, reporting frequency, and identifiers. Until then, the current Annex IV template remains in use.

This means your operational obligations start now, but the reporting format changes come a year later. You need to be collecting the data today that you will be required to report from 2027.

What the Directive Text Confirms

1. Reporting Scope: From Principal to All

2. Delegation Transparency: 8 New Data Points

1. Delegate identification — name, domicile, registered office, and whether they have close links with the AIFM
2. Internal FTEs for portfolio/risk management — number of full-time equivalent staff performing day-to-day management internally
3. Delegated activities — list and description of portfolio management and risk management functions delegated
4. Delegation percentage — amount and percentage of the AIF’s assets subject to delegation arrangements for portfolio management
5. Monitoring FTEs — number of full-time equivalent staff employed to monitor the delegation arrangements
6. Due diligence evidence — number and dates of periodic due diligence reviews, issues identified, and remediation measures
7. Sub-delegation details — parallel information for any sub-delegates in the chain
8. Arrangement dates — commencement and expiry dates of all delegation and sub-delegation arrangements

3. Loan Origination: A New Regulatory Category

4. Liquidity Management Tools: Mandatory from April 2026

5. Leverage and Marketing Disclosures

What’s Still Pending from ESMA

Several critical details will only be determined when ESMA delivers its technical standards (expected April 2027):

• The new XML schema — specific field codes, element names, and validation rules have not been published
• Reporting frequency standardization — the directive mandates harmonization across member states, but the specific calendar is pending
• Identifiers — ESMA will specify identifiers linking reported data to public or supervisory sources
• Granularity of asset/exposure reporting — “all instruments” is confirmed, but the level of detail per instrument is pending
• Loan origination reporting fields — the directive establishes the regulatory category, but the Annex IV reporting structure for loan portfolios is pending

ESMA shall not introduce any additional reporting requirements beyond what the directive mandates. ESMA must also issue a compliance analysis report by April 16, 2029.

Handling the Transition in Code

If you’re building or maintaining an Annex IV XML pipeline, the current ESMA DATAIF v1.2 XSD schema remains valid until the 2027 technical standards are published. The open-annex-iv TypeScript library (Apache 2.0) serializes against the current schema:

import { serializeAnnexIVToXml } from 'open-annex-iv';

const report = {
  aif_identification: {
    reporting_period: { start: '2025-07-01', end: '2025-12-31' },
    aif_name: 'Example Fund I',
    aif_national_code: 'DE000EXA001',
    aif_type: 'PEQF',
    domicile: 'DE',
    inception_date: '2024-01-15',
    aifm_name: 'Example Capital GmbH',
    aifm_lei: '529900EXAMPLE000001',
    reporting_obligation: 'Article 24(1)',
    base_currency: 'EUR',
  },
  investor_concentration: { /* ... */ },
  principal_exposures: { /* ... */ },
  risk_profile: { /* ... */ },
};

const xml = serializeAnnexIVToXml(report);
// Valid ESMA DATAIF v1.2 XML — current schema

When ESMA publishes the new schema, we will update the library to support the expanded field set. In the meantime, start collecting delegation FTE data, LMT activation records, and loan portfolio breakdowns — you will need this data for the 2027 template even though the current schema doesn’t require it.

What to Do Now

1. Select your LMTs. If you manage open-ended AIFs, you must choose at least 2 tools from Annex V and include them in fund documents. This is a legal obligation from April 16, 2026, not a reporting one.
2. Audit your delegation arrangements. Start collecting the 8 data points listed above for every delegate and sub-delegate. You will need this data structured and reportable by April 2027.
3. Classify your loan origination exposure. If originated loans exceed 50% of any AIF’s NAV, you are subject to the new leverage limits (175%/300%) and operational requirements from April 2026. Grandfathering applies to pre-April 2024 AIFs.
4. Prepare for comprehensive exposure reporting. Start capturing all instruments and markets, not just principal positions. The scope expansion is confirmed — only the reporting format is pending.
5. Monitor ESMA consultations. The H2 2026 consultation on RTS/ITS will define the exact Annex IV field specifications. Respond to the consultation if the proposed fields affect your reporting operations.

Sources

• Directive (EU) 2024/927 (AIFMD II) — EUR-Lex
• EY Luxembourg — AIFMD 2.0: What It Means for Annex IV Reporting
• PwC Luxembourg — AIFMD 2: A New Era for Annex IV Reporting
• Walkers — AIFMD II 101: Delegation, Authorisation and Reporting
• Dechert — AIFMD 2.0 Impact on Open-Ended Funds: LMTs
• Paul Hastings — AIFMD II LMT Draft Regulatory Technical Standards
• Arthur Cox — AIFMD II Loan Origination Rules
• BCLP — AIFMD II Leverage Limits and Single Borrower Exposure
• SSC Tech — Preparing for AIFMD 2.0 and Annex IV
• open-annex-iv — Open-source Annex IV XML serializer (npm)