AIFMD II: How Fund Managers Can Prepare for April 2026 Deadline

The EU’s regulatory landscape for alternative investment fund managers (AIFMs) is transforming. With the updated AIFMD II taking effect on April 16, 2026, EU member states are racing to turn these changes into law. But fund managers—both in and outside the EU—need to act now.

From tighter rules on loan-originating funds to expanded delegation and reporting requirements, AIFMD II marks a decisive shift in how regulators expect alternative funds to operate as well as disclose and manage risk. While many firms are still assessing the implications, forward-looking AIFMs are starting to modernize operations and reporting frameworks to stay ahead.

What’s New with AIFMD II?

There are four important new components of AIFMD II:

1. Expanded reporting under NPPR
   For non-EU AIFMs operating under the National Private Placement Regime (NPPR), AIFMD II brings new layers of complexity. Managers must now disclose granular asset-level data, meet enhanced transparency criteria, and comply with tax jurisdiction and AML screening requirements—all while maintaining consistency across reports.
2. Delegation under the microscope
   AIFMs must notify regulators of all delegation and sub-delegation arrangements, ensuring every delegate—regardless of geography or regulation—is in full compliance with AIFMD II. This places a heavier administrative burden on managers relying on third parties to fulfill key operational functions.
3. Loan-originating AIFs face new standards
   For funds involved in loan origination, AIFMD II establishes clear risk retention requirements, borrower limits, and liquidity controls. Managers must implement rigorous policies and maintain transparency around loan-level practices, especially for open-ended structures seeking to justify liquidity.
4. Transparency and fair treatment
   AIFMD II makes it mandatory for AIFMs to disclose all fees, charges, and expenses allocated to the fund—clearly and consistently. It also requires AIFMs to demonstrate that investors are treated fairly, with no hidden economic advantages afforded to select parties.

What Are the Implications for Fund Managers?

The scale and depth of regulatory change brought about by AIFMD II go beyond simple updates. They demand structural shifts in how private equity, private credit, and other alternative fund managers manage compliance. Core challenges include:

• Scaling up reporting workflows to handle expanded disclosures
• Demonstrating substance in delegation and governance models
• Ensuring end-to-end auditability of loan origination processes
• Integrating investor-level fee transparency into reporting packs

How IVP Regulatory Reporting Solution Helps You To Stay Ahead

When regulatory changes are happening rapidly, the IVP Regulatory Reporting Solution delivers a strategic advantage. Trusted by top global asset managers, the IVP Regulatory Reporting Solution is purpose-built to help firms navigate regulatory complexity with agility and control. Designed to adapt to evolving directives like AIFMD II, it enables funds to:

• Automate multi-jurisdictional reporting across AIFMD, Annex IV, and NPPR regimes
• Seamlessly ingest and normalize data from disparate systems and formats
• Track and manage delegation disclosures and governance structures
• Maintain comprehensive audit trails around loan origination and liquidity tools
• Produce investor-ready reporting with built-in transparency controls

Whether you’re preparing for upcoming regulatory submissions or rethinking your long-term compliance infrastructure, the IVP Regulatory Reporting Solution equips you to operate with control and foresight—and without any operational drag.

Act Early, Stay Compliant

AIFMD II doesn’t just raise the bar—it resets it. So while the transposition deadline will not hit until 2026, the time to act is now. Regulatory readiness takes more than just legal interpretation. It requires data readiness, workflow automation, and the right infrastructure to keep pace.

With IVP Regulatory Reporting Solution, funds gain much more than a reporting tool—you gain a partner in resilience. Learn more about how  IVP Regulatory Reporting Solution optimizes outcomes or contact us at sales@ivp.in to set up a live or online demo.