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Future-Proof Your Fund: 6 Key Considerations for the New AIFMD 2.0 Regulations

AIFMD 2.0, the much-anticipated revision of the Alternative Investment Fund Managers Directive, will bring further changes to the alternative investment fund (AIF) sector, including additional rules regarding transparency, stability, and investor protection. Member States will have 24 months to implement AIFMD 2.0 in their national rules. EU-wide implementation can be anticipated by early 2026. Why is this update so significant, and what does it mean for your fund?

Since AIFMD came into force in 2011, the alternative investment fund industry has experienced massive shifts in global economic conditions, the proliferation and growth of new private fund asset classes, and changing international regulatory frameworks. AIFMD 2.0 tackles new challenges that have emerged based on industry developments and feedback from stakeholders while still protecting investor interests and promoting market efficiency.

The following areas are key considerations for AIFMD 2.0, which all alternative investment fund managers should be working to address if they want to remain ahead of regulations:

  1. Loan origination: Remember the slew of loan originations that fueled the 2008 crisis? AIFMD 2.0 wants to prevent a repeat. The new “skin in the game” rules require funds originating loans to hold onto them longer, ensuring they have a stake in their performance. In addition, stricter limits on how much a fund can lend to a single borrower will help to bring stability to the lending landscape.
  2. Liquidity: Don’t get caught short; keep your access to cash robust. AIFMD 2.0 empowers regulators to intervene if they see liquidity risks brewing, ensuring funds have enough cash on hand to weather storms. This is crucial for protecting both investors and the wider financial system.
  3. Depositaries: Keeping a watchful eye on the war chest. Under AIFMD 2.0, depositories will have their role expanded, with broader oversight and stricter reporting requirements. This will help ensure assets are safe and provide investors better peace of mind.
  4. Transparency: Misleading fund names will become a thing of the past. AIFMD 2.0 mandates clear and concise labeling, so investors know exactly what they’re getting into. This promotes fair competition and empowers investors to make informed decisions.
  5. Information flow: AIFMD 2.0 strengthens reporting requirements, ensuring regulators are kept firmly in the loop and have a clearer picture of all fund activities. If adhered to correctly, it will allow them to identify and address potential problems early on, safeguarding investors and the wider investor ecosystem.
  6. Beyond Borders: This update extends beyond EU-based funds. These regulations will also have the reach to extend to non-EU AIFMs marketing within the bloc, ensuring a level playing field and protecting European investors.

Staying Ahead of the Curve

While AIFMD 2.0 is expected to be finalized soon, with implementation likely in 2026, it is crucial to start preparing now.

This means understanding the changes, assessing their impact, and proactively adapting your operations to maintain a strong competitive advantage. Staying ahead of the curve ensures compliance, mitigates risks, and positions a fund for success in the new regulatory landscape.

CSC—Your Navigator in the Regulatory Sea

At CSC, we’re experts in navigating the complexities of the AIFMD landscape. We offer a comprehensive suite of solutions, from fund administration and depositary services to regulatory compliance support.

Remember, staying informed and taking action is key. This blog is just a starting point. Get in touch with our experts today to discuss your specific needs and navigate the AIFMD 2.0 waters with confidence!

Why CSC?

CSC provides tailored administration and strategic outsourcing solutions to support the complex operations of alternative asset managers across jurisdictions and asset types while adhering to global regulations and compliance. A market leader working with funds of all sizes, we’re the trusted partner of choice for 90% of the Fortune 500® and 70% of the PEI 300. Privately held since 1899, CSC is a global company with capabilities in more than 140 jurisdictions. We’re capable of doing business wherever our clients are by employing experts in every business we serve. We are the business behind business®. Learn more at