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What is Changing Under AIFMD 2.0?
Annex IV reporting requirements become significantly more demanding for all EU full‑scope AIFMs, as well as non‑EU AIFMs that market funds into the EU under national private placement regimes. The Directive amends Article 24 (Supervisory reporting) and mandates ESMA to develop Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) that will:
- Replace the current Annex IV template with a harmonized EU format,
- Define reporting frequency and timing to ensure consistency across Member States,
- Specify identifiers to link reported data to supervisory and public sources.
Detailed overview of annex IV changes
- Expanded scope of data: The reporting will move from the current focus on principal markets, instruments, and top exposures to a comprehensive coverage of all markets, instruments, exposures, and assets for each AIF.
- Enhanced data standardization: ESMA will define the identifiers required to connect reported data on assets, AIFMs, and AIFs to other supervisory or publicly available sources. While the exact identifiers will be specified in the RTS/ITS, AIFMs should anticipate stricter requirements for consistent and accurate identification across all reports.
- Harmonized format & submission: A single EU standard XML structure coordinated by ESMA will replace national variations.
- Frequency and Timing — Harmonization Ahead: The related RTS will establish uniform deadlines and processes for supervisory reporting across the EU. While details will come in 2026, AIFMs should prepare for changes to their reporting calendars and processes once these standards are published.
AIFMD 2.0 introduces a significant expansion of Annex IV reporting by adding detailed delegation disclosures and other operational data points that were never required before. These include:
- Human resources metrics:
- Number of FTEs performing portfolio and risk management internally.
- FTEs monitoring delegation arrangements.
- Oversight evidence:
- Dates and outcomes of due diligence reviews.
- Issues identified and remediation timelines.
- Delegation and sub-delegation details:
- Names, domiciles, and regulatory status of delegates and sub-delegates.
- Activities delegated and percentage of assets under delegation.
- Contract start and end dates.
- Marketing footprint:
- Member States where AIF units or shares are marketed by the AIFM or its distributors.
Why This Matters
With more data points and stricter validation rules, the risk of reporting rejections or delays will increase. AIFMs will need to ensure data accuracy across multiple sources (portfolio, HR, compliance) and maintain robust governance to avoid errors.
Key milestones:
- 16 April 2026 – Mandatory deadline for Member States to transpose Directive (EU) 2024/927 (“AIFMD 2.0”) into national law. Luxembourg is on track to meet this deadline: draft Bill No. 8628, which transposes AIFMD 2.0 and UCITS VI, was submitted to Parliament in October 2025
- H2 2026 – ESMA is expected to launch a consultation on the RTS and ITS setting out the new template and harmonized reporting rules.
- 16 April 2027 – Deadline for ESMA to deliver RTS/ITS to the Commission. All AIFMs in scope must start reporting under the new template and harmonized reporting standards thereafter.
How EY Luxembourg Can Help
EY Luxembourg offers end to end managed services for the Annex IV reporting across all jurisdictions, including:
- Gap analysis and readiness assessment to identify new data requirements,
- Automated data collection and validation workflows to reduce manual errors,
- Flexible operating model to adapt quickly once RTS and ITS are finalized,
- Global coverage for Annex IV reporting, ensuring compliance across multiple regulators,
- Continuous monitoring of RTS/ITS developments so you stay ahead of regulatory changes.
Contact with us today to learn how our Managed Services can simplify your Annex IV reporting and keep you ahead of regulatory changes.
Summary
AIFMD 2.0 introduces – amongst others - significant changes to supervisory reporting under Article 24, reshaping the Annex IV content, format, and even reporting frequency and timing through new EU level technical standards. These changes will require AIFMs to manage more granular data, implement stronger governance, and adapt to harmonized processes
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