On 30 October 2024, the Dutch Authority for the Financial Markets (Autoriteit Financiele Markten, AFM) released findings from its exploratory study on the rising number of fund managers operating under the so-called Alternative Investment Fund Managers Directive (AIFMD) light regime. The AIFM-light regime applies to smaller fund managers with assets under €100 million (or €500 million in certain cases) who, unlike fully licensed AIFMs, are exempt from licensing requirements. These managers still adhere to key regulatory obligations, including anti-money laundering measures and annual reporting. The report outlines key trends and characteristics of this part of the market, provides insights into its rapid growth and unique position within the Dutch financial landscape.

Key insights from the AFM’s report include:

• Significant growth: In the last five years, the number of AIFM-light managers increased by nearly 50%, totaling 747, while assets under management rose by 75% to almost €26 billion.
• Retail and international investor base: Retail investors make up 44% of assets in AIFM-light funds, whereas compared to just 3% in fully licensed AIFM funds. A substantial share of AIFM-light investments also originates from international investors, especially in private equity.
• AIFM-Light oversight: While these managers face fewer regulatory requirements, they must fulfill specific obligations, including compliance with the Dutch Sanctions Act and anti-money laundering laws.

For more information, please see the exploratory study.