Report on Operation of AIFMD Highlights Existing Issues

On 10 January 2019, the European Commission (EC) published a report on the operation of the Alternative Investment Fund Managers Directive (AIFMD). The report confirms that AIFMD has significantly contributed to creating a single market for alternative investment funds by establishing a harmonized regulatory and supervisory framework. However, it also identifies various topics that will require further review, including the inconsistent application of rules by National Competent Authorities (NCAs) and issues around reporting, which include the Annex IV requirement. Below are some of the report’s main findings concerning the reporting requirements for firms subject to AIFMD.

Reporting to NCAs

The report highlights that:

  • Reporting obligations differ among NCAs due to differences in rule interpretations or additional requirements
    • These differences in interpretation and filing procedures further exacerbated the costs of reporting
  • Market participants thought that the amount of data required for reporting is disproportionately high
  • The redundancy and duplication of reported data (within AIFMD reports or other regulatory reporting) was also considered a major issue
AIFMD and other EU Legislation

The key topics mentioned about the impact of AIFMD reporting in relation to other regulatory reporting requirements are:

  • A lack of consistency and coherence (use of different reporting details, channels, data repositories and IT standards, problems of collection, issues for regulators in defining systemic risk, implication of ISO 20022, gold-plating and additional requirements by some EU Member States)
  • The need for stronger integration in technological terms (problem of different data standards and formats)
  • Higher costs (compliance costs, distribution costs, running costs, increase in reporting volume and obligations)
  • Duplication (overlap with EMIR, MiFID II, SFTR, the PRIIP KID; along with the need to rationalize and reduce the information requested)
Next Steps

Currently, there are no formal proposed changes to the existing requirements under AIFMD due to the report’s findings. The EC is required by the AIFMD to undertake a review of the Directive, and the EC’s published report represents the first step in this process. The EC will continue its review of the AIFMD and will issue a report to the European Parliament and the Council in 2020. Firms subject to the Directive should review the report and monitor for additional information to come from the EC’s AIFMD review process.


The CSS reporting platform includes solutions for AIFMD, such as Consensus, which helps simplify regulatory reporting through a streamlined design backed by our regulatory expertise. For more information, click here or contact us.


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