AIFMD 2: Quick guide to Member State activity
On 26 March 2024, the final legislative text of the Alternative Investment Fund Managers Directive 2 (AIFMD 2) was published in the Official Journal of the EU. The publication marked the conclusion of the AIFMD Review process that formally began in 2020. AIFMD 2 amends both the AIFMD and the UCITS Directive and makes targeted changes to rules relating to delegation, authorisation requirements, reporting obligations and the regulation of loan originating alternative investment funds. The deadline for Member States to implement AIFMD 2 is 16 April 2026.
In the table below we set out the latest communications from certain Member State regulators regarding their implementation of AIFMD 2 together with any recent updates from the European Commission and European Supervisory Authorities. We also set out the latest communications from the UK as it looks to amend its own implementation of AIFMD.
The table will be updated from time to time.
We have also completed a gap analysis that provides a comparative overview of the key changes introduced by AIFMD 2 as compared to AIFMD and for further details please speak to Claire Guilbert.
| Member State | Latest developments on domestic implementation | NRF contact |
| Germany | On 8 August 2025, the German Federal Ministry of Finance (Bundesministerium der Finanzen – BMF) published its draft bill for the transposition of Directive (EU) 2024/927 (AIFMD 2) into German national law. Entitled Fund Risk Limitation Act (Fondsrisikobegrenzungsgesetz), the draft bill restarts the legislative procedure for implementing the European directive following the election of a new parliament. The BMF intends to implement the directive without any deviations (no “goldplating”) in order to avoid putting the German fund industry at a competitive disadvantage. Last update: 10 January 2026 | Michael Born and Frank Herring |
| Luxembourg | On 3 October 2025, there was published draft legislative amendments to align Luxembourg’s national law with AIFMD 2. The transposition of AIFMD 2 is carried out by amendments to the amended law of 17 December 2010 concerning undertakings for collective investment and the amended law of 12 July 2013 relating to alternative investment fund managers. Furthermore, the Bill makes a specific amendment to the amended law of 17 December 2010 concerning undertakings for collective investment regarding the requirement for a report by an approved statutory auditor for any issue of units in exchange for contributions in kind. Last update: 10 January 2026 | Claire Guilbert |
| France | France has not yet started its AIFMD 2 implementation project. Last update: 10 January 2026 | Sebastien Praicheux |
| Poland | The Polish legislator has not yet started its legislative work implementing AIFMD 2. Last update: 1 August 2025 | Agnieszka Braciszewska |
| Italy | On 8 October 2025, the Government issued a press release regarding the implementation of the AIFMD 2 stating that a draft legislative decree has been submitted by the Government to the Parliament (specifically, the Deputies’ Chamber) for review and approval. An opinion from the Parliament is expected by 25 January 2026. Last update: 10 January 2026 | Maria Gilesi |
| Netherlands | A legislative proposal implementing (among other things) AIFMD 2 – more specifically the Implementation Act for the amended AIFMD and UCITS Directive (Implementatiewet gewijzigde AIFM-richtlijn en icbe-richtlijn) – was submitted to Dutch Parliament on 7 October 2025. Last update: 7 October 2025 | Nikolai de Koning |
| European Commission and European Supervisory Authorities | On 21 October 2025, the European Securities and Markets Authority (ESMA) published its final report and final draft regulatory technical standards (RTS) on open-ended loan-originating alternative investment funds as mandated by AIFMD 2. The draft RTS has been submitted to the European Commission which will make a decision on whether to adopt the RTS within three months or extend that period by one month. On 18 December 2025, ESMA issued a report which makes certain targeted amendments to its guidelines on liquidity management tools (LMTs) of UCITS and open-ended alternative investment funds. The amendments focus on redemption gates and transition costs for anti-dilution LMTs and are intended to align the guidelines with the draft RTS on LMTs under the AIFMD and UCITS Directive which the Commission adopted on 17 November 2025. The Commission’s adoption of the draft RTS included certain amendments to the draft RTS submitted by ESMA. The revised guidelines will be translated into the official EU languages and published on ESMA’s website. The publication of the translations will trigger a two-month period during which Member State competent authorities must notify ESMA whether they comply or intend to comply with the guidelines. The guidelines will apply upon the application date of the draft RTS. Managers of funds existing before the date of application should apply the guidelines in respect of those funds after twelve months from the application date of the draft RTS. Last update: 10 January 2026 | Flupke van den Bogart |
| Non-Member State | ||
| United Kingdom | On 7 April 2025, HM Treasury (HMT) published an open consultation “Regulations for Alternative Investment Fund Managers” setting out the Government’s proposed approach for a streamlined framework for the regulation of AIFMs and the depositories they use. The Financial Conduct Authority has also issued a Call for Input alongside the HMT consultation paper, which indicates its approach to regulating AIFMs within the framework proposed by HMT. For further information please refer to our online briefing note. Last update: 1 August 2025 | Hannah Meakin |
| Norway | On 8 October 2025 the Norwegian Ministry of Finance (Finansdepartementet – MoF) published a consultation paper prepared by the Norwegian Financial Supervisory Authority (Finanstilsynet – NFSA) proposing to implement AIFMD 2.0 into Norwegian national law: Gjennomføring av AIFMD 2.0 i norsk rett. The consultation period ended on 9 January 2026. The responses to the consultation paper are still being processed by the MoF: Høring om gjennomføring av endring av AIFM- og UCITS-direktivene mv. The NFSA has proposed implementing AIFMD 2.0 in its entirety, but with national adaptations where the amending directive allows for this. For example, the proposal provides that: Lending and credit services may not be offered to consumers, and that Norwegian asset managers may not apply to use depositaries from countries other than the fund’s home state for funds established in Norway. AIFs will not be allowed to accept non-professional investors on a “reversed solicitation”-basis. Marketing to “qualified non-professional investors” may be conducted only with marketing authorization, but the AIFM will not be required to conduct a suitability assessment. It is not certain when the final law proposal can be expected, and the MoF has not provided their own estimates. Based on our experience and the MoF’s average processing time, we would expect the law proposal to be presented during the course of late 2026/early 2027. Last update: 5 February 2026 | Advokatfirmaet Schjødt AS Klaus Henrik Wiese-Hansen, Partner and Attorney admitted to the Supreme Court Ingrid Austjore Valseth, Attorney |