Finanstilsynet Issues Changes to AIFMD Reporting
The Financial Supervisory Authority of Norway (Finanstilsynet) has recently updated its filing methodology with the introduction of Altinn.no, a new system to ease reporting obligations for AIFMs. In place of the previous submission mechanism through SFTP, Altinn.no allows AIFMD reporting to be completed with the option for users to choose between uploading by XML or manually inputting AIFM/AIF data directly in the system. With this, however, there have been no changes to the XML schema or deadlines for submission.
As a result of these new system-based updates, all AIFMD filers for Norway must add their user to the Altinn.no database and because alternative investment managers are now only permitted one account per guidelines, usernames should be rather generic. In addition to this, third parties can no longer have their account set up on behalf of the client filing firm.
All registration and login-based details can be accessed via Finanstilsynet’s website.
Obligations for Non-Quarterly Filers
Apart from the regular H1/H2 form submission by semi-annual filers and yearly form submission by annual filers, any AIF that is authorized to market in Norway is now required to submit an additional two forms: Form KRT-1161 for the AIFM and Form KRT-1160 for each AIF in the remaining quarters (Q1 and Q3 for semi-annual filers, and Q1, Q2 and Q3 for annual filers). Both of these forms have a simple web-based schema that is only available in the Altinn.no environment. With access granted three weeks prior to the deadline of each quarter, most of the information required in these forms is generally static apart from quarterly AUM data, allowing them to be auto-populated.
There is no additional reporting obligation for quarterly filers.
What’s Not Required?
The XML file will no longer require users to input static information such as name, address and contact details since it will already be preloaded in the Altinn.no system. Additionally, the system won’t anticipate any peculiar naming convention despite this being previously expected.
Instead of reporting fund-based information on an aggregate basis, a separate XML for each fund must be uploaded in the portal.
These updates will become effective in January 2021, meaning that all upcoming AIFMD filings from the reporting period ending on the 31st of December 2020 for Q4/H2 or Y1 filings must be submitted through www.Altinn.no.
XSDs and Sample Files
XML Forms AIF001 and AIF002 are to align with the ESMA technical guidance taxonomy Version 1.2. Below are the XSDs and sample files for reference:
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