AIFMD II Compliance Checklist: Everything Fund Managers Must Do Before April 16, 2026
The clock is ticking. Directive (EU) 2024/927 — commonly known as AIFMD II — must be transposed into national law by April 16, 2026. For Alternative Investment Fund Managers (AIFMs) across Europe, this means material changes to delegation arrangements, reporting obligations, liquidity management, investor disclosures, and more.
Whether you're a German KVG filing with BaFin, a Luxembourg AIFM under CSSF oversight, or an Austrian manager reporting to FMA, this checklist covers every requirement you need to address. We've organized items by priority and linked each to practical implementation guidance.
Not sure where you stand? Run Caelith's free AIFMD II Readiness Assessment to get a personalized gap analysis in under 5 minutes.
The Checklist: 8 Areas You Must Address
1 Delegation Arrangements Review
What changed: AIFMD II introduces stricter substance requirements for AIFMs that delegate portfolio management or risk management. Article 20 now requires that the AIFM retains sufficient resources, expertise, and decision-making authority to effectively supervise delegated functions. AIFMs must demonstrate they are not "letterbox entities."
What you must do:
- Review all delegation agreements for compliance with the new substance requirements
- Document that your firm has at least two senior managers resident in the home Member State
- Ensure you can demonstrate active oversight of delegated functions (meeting minutes, escalation procedures, performance reviews)
- Prepare for enhanced ESMA reporting on delegation arrangements
Automation: Caelith's Compliance Copilot can analyze your delegation agreements and flag gaps against AIFMD II substance requirements.
2 Annex IV Reporting Changes
What changed: The Annex IV reporting template under AIFMD II includes expanded fields for delegation reporting, loan origination activities, liquidity management tools, and enhanced leverage calculation. The ESMA XSD schema has been updated to Rev 6 (AIFMD_DATMAN_V1.2.xsd).
What you must do:
- Map your fund data to the updated Annex IV taxonomy (now 147+ fields)
- Update your XML generation process to comply with the new XSD schema
- Test validation against ESMA's official XSD before your first post-transposition filing
- Confirm your NCA portal credentials are active (BaFin MVP Portal, CSSF eDesk, etc.)
Automation: Caelith's BaFin Filing Agent generates XSD-validated Annex IV XML and submits directly to BaFin's MVP Portal. See our complete Annex IV filing guide.
3 Liquidity Management Tools (LMTs)
What changed: AIFMD II requires open-ended AIFs to have at least two liquidity management tools available from a prescribed list (Article 16). These include redemption gates, notice periods, redemption fees, side pockets, and swing pricing. At least one must be a tool other than suspension of redemptions.
What you must do:
- Select and implement at least two LMTs from the ESMA-prescribed list
- Update fund documentation (prospectus, offering memorandum) to reflect LMT policies
- Establish activation thresholds and governance procedures for each LMT
- Notify your NCA of the LMTs you've selected
- Ensure your Annex IV reporting captures LMT information in the new required fields
4 Investor Disclosure Updates
What changed: Enhanced pre-investment and periodic disclosure requirements under Article 23. AIFMs must now disclose all fees and charges (direct and indirect) borne by the AIFM that are passed on to the AIF or its investors. New cost transparency requirements align with PRIIPs-style total cost reporting.
What you must do:
- Review and update your Article 23 investor disclosures
- Create a comprehensive fee schedule covering all direct and indirect costs
- Update periodic investor reports with enhanced cost breakdowns
- Generate EMT/EET/EPT templates with the updated cost data
Automation: Caelith generates EMT/EET/EPT templates from your structured fund data, ensuring cost disclosures meet the new requirements.
5 Depositary Agreement Updates
What changed: AIFMD II extends depositary passport-like arrangements in specific circumstances and clarifies depositary liability rules. For cross-border AIFs, the depositary regime is being harmonized, and there are new requirements for depositaries of loan-originating AIFs.
What you must do:
- Review depositary agreements for compliance with updated liability provisions
- If you manage loan-originating funds, confirm your depositary arrangement meets the new requirements
- Update depositary reporting schedules to align with enhanced Annex IV timing
6 Loan Origination Framework (If Applicable)
What changed: AIFMD II introduces a comprehensive framework for loan-originating AIFs for the first time. This includes risk retention requirements (5% of notional value of each originated loan), concentration limits (20% of AIF capital to a single borrower), and restrictions on lending to related parties.
What you must do:
- Classify your AIFs: do any originate loans as defined under AIFMD II?
- Implement 5% risk retention tracking per originated loan
- Monitor and report concentration limits against the 20% threshold
- Establish policies for related-party lending restrictions
- Update Annex IV reporting to include loan origination-specific fields
7 Cost Transparency and Fee Reporting
What changed: Building on MiFID II's cost transparency framework, AIFMD II requires AIFMs to report all costs and charges in a standardized format. This includes performance fees (with a clearer calculation methodology), management fees, depositary fees, administration fees, and any other costs passed to investors.
What you must do:
- Audit all fee structures across your AIF portfolio
- Standardize fee reporting format across all fund documentation
- Verify performance fee calculations meet the new methodology requirements
- Update investor reporting templates with disaggregated cost information
8 NCA Notification and Registration Updates
What changed: AIFMs must update their NCA registrations to reflect AIFMD II compliance. This includes updated organizational information, delegation arrangements, LMT selections, and any changes to the scope of authorized activities (particularly if you've added loan origination).
What you must do:
- Prepare updated AIFM notification packages for your home NCA
- Update marketing passports if your investor disclosures have changed materially
- Confirm all fund registrations are current in your NCA's database
- Test your NCA portal access and submission process well before the deadline
Timeline: What to Do When
Now – March 2026: Complete items 1, 4, 5, and 7 (documentation and agreement updates). These are prerequisites for everything else.
March 2026: Address items 2 and 3 (Annex IV updates and LMT implementation). Test XML generation against the new XSD schema.
April 1-16, 2026: Complete items 6 and 8 (loan origination framework and NCA notifications). Final testing of all filing processes.
April 16, 2026 — Transposition Deadline: AIFMD II is live. Your first compliant Annex IV filing will be due based on your reporting frequency (quarterly = July 2026, semi-annually = October 2026, annually = April 2027).
How Much of This Can Be Automated?
Realistically, about 60-70% of this checklist involves structured, repeatable tasks: XML generation, data mapping, template creation, validation testing. These are exactly the tasks that compliance AI agents handle best.
The remaining 30-40% — reviewing delegation agreements, making governance decisions about LMTs, negotiating depositary terms — requires human judgment. But even here, AI can accelerate the process by analyzing your existing agreements, flagging specific gaps against the new requirements, and generating first drafts of updated documentation.
Check Your AIFMD II Readiness in 5 Minutes
Caelith's free readiness assessment analyzes your fund structure against all 8 checklist areas and generates a personalized remediation plan.
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