AIFMD II Readiness Checklist: What to Do Now, Next, and Before April 2027

For most EU-regulated alternative investment managers, April 2026 passed quietly. For compliance teams, however, it marked the transposition deadline for AIFMD II and the start of active scrutiny by national competent authorities (NCAs).

Several of the directive’s core requirements are not aspirational targets. They are firm obligations as of transposition. That means firms that treated the April deadline as a soft target may now be operating with incomplete delegation registers, undocumented liquidity management tool (LMT) policies, and fee disclosures that do not meet the revised standard.

To help firms establish a more precise and actionable AIFMD II readiness plan, here are 12 actions your team can take across three time horizons: overdue items, near-term tasks, and parallel-running requirements ahead of the April 2027 Annex IV go-live.

What Changed in AIFMD II and Why the Timeline Is Now Compressed

AIFMD II (Directive 2024/927/EU) amended the original 2011 framework across several dimensions: liquidity risk management, delegation oversight, substance requirements, cost transparency, and the Annex IV reporting template. EU member states were required to transpose the directive by April 16, 2026.

This deadline effectively opened the compliance window. ESMA’s new Annex IV reporting template is not expected until H2 2026, with the revised template going live in April 2027. But the operational and governance changes required to support that filing must be established now, not when the template drops.

Many NCAs, particularly the CSSF in Luxembourg, the Central Bank of Ireland, and the AFM in the Netherlands, have signaled they are already reviewing LMT policies, delegation disclosures, and substance positions. In other words, the review cycle is active, not pending.

Time Horizon 1: Overdue as of April 2026

Four items were due at the time of transposition. If any of these remain incomplete, treat them as immediate remediation tasks.

1. LMT policy in writing
   AIFMD II requires open-ended AIFMs to select at least two LMTs from the ESMA-approved list, calibrate those tools for each relevant AIF, and document the governance framework in writing. EC Delegated Regulations 2026/465 and 2026/466 set out detailed operational requirements. NCAs expect to see this documentation on request.
2. Updated and complete delegation register
   Article 20’s revised delegation framework requires AIFMs to maintain a structured register for all delegated functions: percentage of activity, delegate entity, oversight methodology, and commencement date. Sub-delegation relationships must be disclosed with the same specificity.
3. Substance check: two qualified persons
   AIFMD II tightened the substance requirement for EU-domiciled AIFMs. At minimum, two full-time senior individuals based in the EU must be conducting AIFM business. For firms relying on thin EU presences, this is the closest area of regulatory attention.
4. Fee and cost disclosures under revised Article 23
   All direct and indirect fees, charges, and costs borne by investors, at both the AIFM and AIF level, must be itemized and disclosed consistently. This is not a new principle, but a new level of granularity. Templates that were acceptable under AIFMD may not meet the revised standard.

Time Horizon 2: Now Through October 2026

ESMA is expected to publish the revised Annex IV ITS during H2 2026, with the new template applying to any filings submitted from April 2027 onward. Firms that wait for the template to arrive before starting to build out the required data infrastructure will not have enough time.

1. Build out instrument and market data coverage
   The revised Annex IV is expected to expand the scope of reportable positions beyond the current “principal market only” basis. Firms should map current data feeds against the anticipated new fields and identify coverage gaps now.
2. Add EEA marketing registrations to the regulatory data model
   Marketing passport data, which covers which member states each AIF is registered for marketing and on what basis, needs to be captured in a structured form that feeds directly into Annex IV. This data often sits in disconnected legal records rather than the reporting system.
3. Map leverage calculations using the commitment method for all EEA-marketed AIFs
   Leverage reporting under the revised Annex IV is expected to require commitment-method calculations for all EEA-marketed funds, not just those above current thresholds. Firms should run the calculations now to identify data and methodology gaps before the template goes live.
4. Engage in the ESMA consultation on Annex IV RTS when it opens
   ESMA’s consultation on the revised Annex IV RTS is expected to open in H2 2026. Firms can help protect their reporting model by responding. The definitions in the final ITS are shaped by consultation responses, so missing the window would be a tactical error.

Time Horizon 3: October 2026 Through April 2027

1. Run parallel Annex IV filings under the new template
   Once ESMA publishes the revised ITS, firms should run existing filings in parallel under both the old and new templates. Discrepancies between the two will reveal data mapping issues that are much easier to resolve before the hard go-live.
2. Update LMT documentation to align with Delegated Regulations 2026/465–466 in detail
   The Delegated Regulations set out more granular operational requirements for LMT calibration, governance, and investor communication than most other LMT policies. Documentation updates should be completed well before April 2027, not in the weeks prior.
3. Commission a UCITS supervisory reporting readiness assessment
   The UCITS supervisory reporting framework is expected to follow the AIFMD Annex IV template closely. Firms managing both UCITS and AIF structures should not treat AIFMD II reporting as a separate project. The data architecture built now should be reusable for the UCITS wave.
4. Engage NCAs directly on open-ended fund structure, if applicable
   Firms operating open-ended, long-only AIFs should not wait for the October 2027 RTS on open-ended LO fund requirements. NCAs have discretion to apply requirements earlier, and early engagement reduces the risk of a retroactive compliance review.

How IVP Supports AIFMD II Compliance

These 12 steps are compliance obligations. Executing them across multiple fund structures, jurisdictions, and data systems is where the technical work happens.

The IVP Regulatory Reporting Solution supports AIFMD II compliance operations across the full filing lifecycle:

• Automates multi-jurisdictional filings, including Annex IV, NPPR, and AIFMD II submissions, across 30+ global regulatory templates
• Tracks and discloses delegation and sub-delegation relationships through structured registers aligned to Article 20
• Populates and validates loan-level data fields and liquidity metrics in line with AIFMD II Annex IV and LMT calibration requirements
• Integrates investor fee data and generates consistent, Article 23-compliant cost disclosures
• Maintains complete audit trails from data ingestion through submission and NCA acknowledgement
• Generates encrypted XML submissions to meet local NCA technical requirements across ESMA, CSSF, CBI, and other regulators

For firms approaching the April 2027 Annex IV go-live without a structured data and filing infrastructure, the operational window is narrowing rapidly. Contact us today to learn more about prioritizing these actions and how the IVP Regulatory Reporting Solution speeds the process.