On 9 April 2025, a public consultation was launched for the draft bill to implement the revised Alternative Investment Fund Managers Directive (Directive 2011/61/EU, the AIFMD) and the Undertakings for Collective Investment in Transferable Securities Directive (Directive 2009/65/EC, the UCITS Directive).

The draft bill introduces new rules for alternative investment funds (AIFs) engaging in lending, including loan-originating AIFs. It also updates existing liquidity management requirements for AIFs and collective investment in transferable securities (UCITS). Under the draft bill, management companies of open-ended AIFs and UCITS will be required to implement at least two liquidity management tools from the list in Annexes of the the revised AIFMD and UCITS Directive (e.g. redemption gates, redemption fees, or notice periods). These tools must also be embedded in the fund’s rules or constitutional documents to ensure transparency for investors.

In addition, the draft bill sets out revised requirements for liquidity management, reporting obligations, outsourcing arrangements, and cross-border custodial services for AIFs and UCITS.

The consultation is open until 8 May 2025. The draft bill and accompanying explanatory notes are available (in Dutch only) via this link.