AIFMD II is coming
Turn AIFMD II into an advantage with an AIFM that expands your EU fund distribution ahead of the 30 April 2026 deadline
AIFMD II and UCITS VI will take effect across the EU on 16 April 2026. AIFMD II will impact delegation, liquidity management tools, and ancillary services. For asset managers accessing EU capital, early preparation is not just about compliance, it is a strategic advantage.
Acting now ensures firms are operationally aligned, competitively positioned, and fully prepared as regulatory expectations and investor scrutiny continue to rise.
What are the key changes under AIFMD II
- Strengthened delegation oversight
- New loan-origination framework with leverage limits and risk retention (source turn1search3)
- Liquidity Management Tools are now required
- Enhanced cross-border supervision and reporting
- Alignment with UCITS
- Marketing restrictions for high-risk jurisdictions
Compliance Deadlines
- Directive in force: 15 April 2024
- Transposition deadline: 16 April 2026
- Operational preparation window until April 2026
How Altum Management Company Can Support
- Regulatory readiness & gap analysis
- Delegation governance & substance support
- Loan-origination framework implementation
- Liquidity management tools & stress testing
- Enhanced reporting (Annex IV & delegation)
- Cross-border marketing compliance / (Pre-) marketing process
Perspectives from our experts
Pierre Goes, Managing Director at Altum Management Company:
“AIFMD II marks a pivotal evolution in Europe’s regulatory landscape, raising the bar for governance, transparency and investor protection.
Its new requirements, particularly around delegation, liquidity and loan origination, will challenge managers, but also strengthen market resilience
At Altum, we see AIFMD II as an opportunity to partner even more closely with our clients — guiding them through the changes and ensuring they remain fully compliant and operationally confident.”
Perspectives from our experts
Christophe Chanudet, Conducting Officer in charge of Risk & Valuation at Altum Management Company
“AIFMD II significantly strengthens liquidity risk management expectations, requiring more rigorous liquidity stress testing and solid governance over liquidity management tools (LMTs) so they can be activated promptly in stressed markets.
For loan‑originating AIFs, AIFMD II tightens credit risk controls—demanding embedded origination policies, clearer risk limits, and concentration/portfolio safeguards as part of the core risk framework.”
Altum Management Company Luxembourg SA views these developments as a driver to elevate our risk model, enhance client outcomes, and further distinguish our control environment.”
Heike Morgenroth, Associate Director, Luxembourg:
“AIFMD II raises the bar on harmonising loan‑origination rules, deepening liquidity management discipline, and elevating delegation oversight, giving investors stronger protection, clearer insight, and greater confidence.
AIFMD II transforms compliance from a burden into a strategic advantage for managers and strengthens investor confidence. At Altum we can take care of the reporting requirements, supporting managers by turning these into a seamless process and delivering accurate reporting with robust operational support especially when it comes to the enhanced reporting for Annex IV.”
Daniel Gillett, Head of Funds & Institutional Jersey:
“AIFMD II represents a step‑change for loan‑originating funds. The new harmonised framework around risk retention, leverage limits and credit risk management will demand far greater discipline from manager, both operationally and in how they evidence robust governance. For firms that are prepared, these rules don’t just enhance investor protection; they create a clearer, more stable environment for lending strategies to scale sustainably across Europe. At Altum, we’re helping managers translate the regulatory detail into practical implementation so they can stay ahead of the curve and continue to originate credit with confidence.”
If you’re planning your AIFMD II transition, we’re ready to help you navigate the changes with confidence.
Let’s talk. Reach out to our experts to find out more.
