In May 2020, a bill was passed in the Icelandic parliament making AIFMD filing mandatory for Alternative Investment Fund Managers (AIFMs) that are authorized or registered by the Icelandic Financial Supervisory Authority (FSA). Regardless of whether the AIF is open-ended or close-ended, this requirement is applicable to all managers who market or operate single or multiple AIFs in Iceland or other EEA states.
In order to comply, the filing must be done in an Extensible Markup Language (XML) format that validates against the ESMA schemas and guidelines. Although reporting starts from 2021, the first report is required to be submitted before January 31st, 2021 for eligible funds for the reporting period ending on December 31st, 2020. For Q1 2021, the submission due date is 30th April, 2021.
While the submission format is standard and does not require additional covers, encryptions or naming conventions, the submission process and set up depends on the location and nationality of the reporting entity, as described below:
- Icelandic Entities
Reporting entities located in Iceland receive log-in information directly from the Financial Supervisory Authority of the Central Bank of Iceland (FSA Iceland) and are responsible for setting up access for their service providers. For instructions on how to submit data using the Icelandic FSA (FME) web service, click here.
- Non-Icelandic Entities
Non-Icelandic entities located outside of Iceland must currently submit their AIF/AIFM reports via e-mail to firstname.lastname@example.org. There are no strict naming conventions required for the files except for the extension (.xml), and there are reasonable limits to the length of the name. Third parties can also submit their reports to email@example.com on behalf of reporting firms but must indicate to which registered party the data belongs.
IVP’s regulatory reporting solution, Raptor, takes a forward-looking approach to jurisdictional changes, making transitions like this completely seamless with an easy one-time static data setup. It provides any reporting party that is struggling with the nuances of AIFMD with the ability to generate XMLs that comply with multiple jurisdictions using a single data input.
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