April 16 came and went.
For most alternative fund managers, this date involved months of internal pressure, rushed gap assessments, and compliance workarounds that were never meant to be permanent. The deadline was met (more or less) and the team has moved on.
That is exactly the wrong response.
AIFMD II is not a box to check. It is a two-phase regulatory transformation, and the second, much more demanding phase, still looms ahead.
What Requirements Are Live Right Now?
The April 16 transposition date activated a set of operational obligations that have no deferral and are fully enforceable today. They include the following:
Liquidity management tools (LMTs) are now a formal requirement. AIFMs must select appropriate tools from the harmonized EU list, have governance frameworks in place for activation, and be prepared to notify National Competent Authorities (NCAs) when tools are used. This requires documented policies, board-level sign-off, and operational workflows that many firms had not fully built by the deadline.
Delegation is under significantly tighter scrutiny. NCAs expect detailed disclosure of delegation arrangements, including substance requirements at the delegate level. Funds with complex sub-delegation structures have the most exposure.
Loan origination AIFs now operate under a formal regulatory framework for the first time. Highlights include leverage limits (300% for open-ended, 175% for closed-ended), a 20% single-borrower concentration cap, and mandatory conflict of interest policies.
Depositary oversight obligations have also expanded. This change is particularly focused on asset verification and liability frameworks for third-country depositaries.
Firms that treated these requirements as simple checkbox exercises are now facing the most cleanup work for phase two.
Preparing for the Bigger Shift in April 2027
Here is what most funds have not yet accounted for in their plans.
As of April 16, 2027, full Annex IV supervisory reporting under ESMA’s new XML templates becomes mandatory across all EU NCAs. The new schema significantly expand data fields, standardize reporting structure across jurisdictions, and remove the discretion many firms have relied on to manage gaps in data infrastructure.
In fact, several EU member states are already applying enhanced Annex IV granularity under national transpositions ahead of the EU-wide date. If your fund reports to multiple NCAs, enhanced requirements may already apply in at least one jurisdiction.
Here’s what really matters: the data infrastructure and reporting workflows required to meet the 2027 templates can’t be built in the last quarter before the deadline. Firms that will make it past April 2027 without a crisis are the ones starting work now.
What Are Regulators Watching?
ESMA’s supervisory convergence agenda means NCAs are sharing data and benchmarking supervisory approaches across borders. That means inconsistencies in how funds report across jurisdictions will be increasingly visible.
The areas drawing the most intense scrutiny right now include LMT governance documentation, delegation substance, and data quality in Annex IV submissions. If your firm took operational shortcuts during a rushed transposition period, this is where they will show up.
Beyond the EU, SEC Form PF amendments and enhanced liquidity risk disclosure requirements are reinforcing the same regulatory themes globally. In other words, buy-side firms operating across jurisdictions are no longer managing regional requirements in isolation.
What Good Looks Like From Here
Firms managing AIFMD II successfully share a few characteristics.
- They have retired workarounds. Manual processes and spreadsheet-based quick fixes made for April 2026 are now being replaced with automated data pipelines and structured reporting workflows.
- They are mapping current Annex IV reporting against the new ESMA XML schema. Doing this now gives teams enough time to identify data gaps before they become a crisis.
- They are treating LMT governance as an ongoing operational process, not a static policy document. Activation decisions and NCA notifications need workflow infrastructure behind them.
- They are doing all this without adding headcount. Automation and managed services mitigate complexity, allowing compliance teams to focus on judgment, not data assembly.
Solving AIFMD II with the IVP Regulatory Reporting Solution
The IVP Regulatory Reporting Solution is specifically designed to handle the complexity AIFMD II introduces across both phases.
On the operational side, it automates LMT governance workflows, tracks delegation disclosures, and manages NCA notification requirements without the need for manual intervention. On the reporting side, it is already aligned to ESMA’s new Annex IV XML schema, so firms building toward the 2027 mandate are not starting from scratch.
What that enables in practice:
- End-to-end Annex IV reporting, from data ingestion to NCA submission, with full audit trails
- Pre-built templates mapped to ESMA’s XML structure, ready for the 2027 transition
- Automated data validation and reconciliation, reducing reporting errors at the source
- Managed services that absorb operational complexity without increasing headcount
The Window That Matters
The time between April 2026 and April 2027 is absolutely critical for AIFMD II readiness.
Firms that use this window to close operational gaps, build toward the ESMA XML reporting standard, and modernize compliance infrastructure will be well-positioned. Those who are treating April 2026 like the finish line will face a difficult 2027.
The question is not whether the work needs to be done. It is whether it gets done on your own timeline or the regulator’s.
If these issues are affecting your firm, Indus Valley Partners is hosting a webinar on June 23 to explore the full AIFMD II two-phase compliance structure, including where firms stand today and what realistic preparation for 2027 looks like. [Register here]
