The recent publication by the AMF — entitled ‘The AIFM 2 Directive’ — summarises the expected changes to the European framework applicable to management companies and investment funds.
Why is this summary worthy of your attention?
It provides a structured and accessible overview of the main changes introduced by the directive, making it a useful resource for both asset management company executives and compliance and internal control teams.
It is published by the AMF, ensuring that the information is reliable and up to date.
It anticipates the regulatory transposition period (set for 16 April 2026) and allows the parties concerned to prepare their internal systems.
It highlights both the changes common to the AIFM Directive and UCITS Directive frameworks and the specific adaptations for alternative investment funds (AIFs).
In short, this publication should be seen as a strategic starting point for management companies wishing to align their future practices, identify drivers of change and assess their level of preparedness.
Key developments to anticipate
Here are the key points highlighted in the AMF summary:
1. Broader scope
The AIFM 2 Directive will simultaneously revise the AIFM Directive and the UCITS Directive.
This will affect: AIF management companies authorised under the AIFMD, as well as UCITS management companies authorised under the UCITS Directive.
2. Timetable for transposition and application
Transposition into French law must take place by 16 April 2026 at the latest.
Additional reporting obligations (to the AMF) are planned to come into force on 16 April 2027.
3. Provisions common to UCITS and AIF management companies
Strengthening of the supervision of delegation and sub-delegation mechanisms: the management company will be required to provide more detailed information (on the delegate, human/technical resources, the scope of the delegation, etc.).
New liquidity management tools imposed on all open-ended funds (UCITS or AIFs): suspension of subscriptions/redemptions, gates (capping of redemptions), extension of notice periods, swing pricing, dual pricing, redemption in kind, side pockets.
At least two liquidity tools must be implemented (except for money market funds, which may adopt only one). Find more details in our article dedicated to LMTs here.
4. Specific developments relating to AIF management companies
The granting of loans by AIFs is now regulated: implementation of credit risk policies/procedures, limitation to an individual borrower (notional ≤ 20% of the AIF’s capital, if the borrower is a financial company/AIF/UCITS).
AIF leverage is capped: 175% for open-ended funds, 300% for closed-ended funds.
Obligation to retain 5% of the notional value of loans transferred to third parties.
5. Enhanced governance and reporting
The two physical managers of an asset management company must be domiciled in the European Union and work full-time for the company (employees, executive members or board members).
Reporting to the competent authorities is strengthened: European reporting comparable to that of AIFs is extended to UCITS, and the European Securities and Markets Authority (ESMA) must submit technical standards by 16 April 2027.
Conclusion
This AMF publication is an essential monitoring tool for your teams: it clearly identifies deadlines, upcoming obligations and areas requiring vigilance, while remaining concise and focused. It enables you to start thinking strategically today about governance, liquidity, delegation, new services and reporting.
We invite you to consult the dedicated AMF page directly via this link: AIFM Directive 2, where you will find details, the relevant texts and the latest annexes.
CerLab Finance supports asset managers and institutional investors in preparing for these regulatory developments, through tailored regulatory due diligence, internal framework reviews, and strategic sectoral monitoring.