AIFMD II Changes Everything from Delegation to Reporting.
Are You Prepared?
Trustmoore's teams in Luxembourg help fund managers navigate the operational shift before April 2026.
AIFMD II Changes Everything from Delegation to Reporting.
For fund managers running Luxembourg vehicles, AIFMD II is not a single compliance task but an operational overhaul across multiple workstreams at once.
- New delegation registers.
- Liquidity management tools that need selecting, documenting and testing.
- Formalised loan origination policies.
- Enhanced Annex IV reporting infrastructure that must be collecting data well before the April 2027 deadline.
Trustmoore's fund administration and AIFM/ManCo teams work alongside fund managers to structure and execute this transition, so your operations stay on track while the regulatory landscape shifts around them.
1. Broader Delegation Oversight
Delegation rules now cover fund administration, marketing and loan origination alongside portfolio and risk management. Fund managers need comprehensive oversight registers and must be prepared to report detailed staffing and due diligence data from April 2027.
2. New Liquidity Tools for Open-Ended AIFs
Every open-ended AIF must have at least two liquidity management tools selected and operationally ready. This includes structures that allow redemptions before liquidation, which may bring semi-liquid vehicles into scope as well.
3. A New Framework for Private Credit
The first EU-wide framework for loan-originating AIFs introduces risk retention, concentration limits and leverage caps. Luxembourg has confirmed that loan origination is a permitted AIFM activity, providing greater legal certainty for cross-border lending.
4. More Granular Regulatory Reporting
Annex IV reporting expands significantly, with new data points covering delegation arrangements, internal staffing levels and due diligence outcomes. Although reporting begins in April 2027, the data collection groundwork starts now.
Trustmoore’s teams in Luxembourg combines fund administration with AIFM and Management Company services to support the full fund lifecycle. From regulatory reporting and compliance frameworks to delegation oversight and operational governance, our team manages the processes that allow fund managers to focus on their investment strategy.
Get a clear picture of what AIFMD II means for your fund's operations and how to prepare. Fill out the form and a member of one of our Luxembourg fund services teams will be in touch you.
Looking for the regulatory detail? Read our full analysis of AIFMD II, Draft Bill 8628 and CSSF Circular 25/901.
