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: 11 August 2025 | 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: 3 October 2025 | Claire Guilbert |
| France | France has not yet started its AIFMD 2 implementation project. Last update: 1 August 2025 | 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. At the time of writing no precise timeline has been specified but considering the Government’s sound majority in Parliament and the technical nature of the decrees, the process may not be too long. Following approval by the Deputies’ Chamber, the same text then needs to be approved by the Senate. Last update: 8 October 2025 | 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 6 October 2025, the European Commission announced that it will not be adopting certain level 2 measures until after 1 October 2027. From an AIFMD 2 perspective this includes: RTS on open-ended Loan Originating Funds (mandate under Art. 16(2f)). ITS on exchange of information between NCAs, the ESAs, the ESRB, and members of the ESCB (Art. 101(9)). ITS on exchange of information between NCAs, the ESAs, the ESRB, and members of the ESCB (Art. 50(6)). Last update: 15 October 2025 | 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 |