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 | In Germany, the previous Government had started the national implementation of AIFMD 2. The Fund Market Strengthening Act (Fondsmarktstärkungsgesetz – FoMaStG) was intended to transpose the European Directive into national law. However, due to the collapse of the previous Government and the new elections, the new Parliament must start a new legislative procedure. Last update: 20 June 2025 | Michale Born and Frank Herring |
| Luxembourg | In Luxembourg, the legislative process for the preparation of the bill of law implementing AIFMD 2 has apparently started, but it has not yet been published. However, the Commission de Surveillance du Secteur Financier (CSSF) has been actively updating its regulatory framework and guidance documents recently, clearly in anticipation of the changes introduced by AIFMD 2. For example: The CSSF published an updated version (Version 24, dated 20 May 2025) of its FAQs on the Law of 12 July 2013 on alternative investment fund managers (AIFMs), which includes clarifications and modifications that likely align with the upcoming AIFMD 2 requirements. The CSSF has detailed the procedures for marketing alternative investment funds (AIFs) in Luxembourg, including notification and de-notification processes, in line with the Cross-Border Distribution Framework and anticipated AIFMD 2 provisions. Last update: 20 June 2025 | Claire Guilbert |
| France | France has not yet started its AIFMD 2 implementation project. Last update: 20 June 2025 | Sebastien Praicheux |
| Poland | The Polish legislator has not yet started its legislative work implementing AIFMD 2. Last update: 20 June 2025 | Agnieszka Braciszewska |
| Italy | The approval of the framework legislation for AIFMD 2 is currently pending before the Parliament (more precisely, at the Deputy’s Chamber (Camera dei Deputati) after being approved by the Republic’s Senate (Senato della Repubblica)). It consists in the delegation of powers to the Government for the adoption of implementing legislation. Last update: 20 June 2025 | Maria Gilesi |
| Netherlands | The legislative proposal for the act implementing AIFMD 2 is still being prepared. A draft legislative proposal was published for consultation on 9 April 2025 and the consultation closed on 8 May 2025. The legislative proposal has not yet been submitted to the Dutch Parliament. Last update: 20 June 2025 | Nikolai de Koning |
| European Commission and European Supervisory Authorities | ESMA Discussion Paper on the integrated collection of funds’ data On 23 June 2025, European Securities and Markets Authority (ESMA) launched a Discussion Paper on the integrated collection of funds’ data. See our Global Regulation Tomorrow blog here. ESMA provides technical advice on the UCITS EAD On 26 June 2025, ESMA published a Final Report containing technical advice to the Commission on the review of the UCITS Eligible Assets Directive. See our Global Regulation Tomorrow blog here. Last update: 26 June 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: 20 June 2025 | Hannah Meakin |