Introduction
The European Securities and Markets Authority (ESMA) created the Data Quality Engagement Framework (DQEF) to improve the accuracy, consistency, and timeliness of regulatory data collected under the Alternative Investment Fund Managers Directive (AIFMD).
It sets out an EU-wide process that continuously checks the completeness and credibility of data reported by managers and funds to both national authorities (NCAs) and ESMA’s own systems.
Reliable, consistent data is critical for EU supervision, systemic-risk monitoring, and investor protection.
However, meeting DQEF standards is complex: each dataset must pass more than forty automated tests, many cross-referencing other databases such as GLEIF, ECB RIAD, or MiFID FIRDS.
Working with a specialised AIFMD-reporting provider that has already implemented the DQEF logic avoids frustrating “back-and-forth” exchanges with NCAs, ensures compliance on the first submission, and saves weeks of manual corrections.
Completeness Tests
AIFMR_DQT_1001000 – File Transmission: Register
Ensures all register files are received.
Triggers: When expected register files are missing or not transmitted within the period.
AIFMS_DQT_1001100 – File Transmission: System
Counts files received in ESMA’s AIFMD system.
Triggers: When a country or manager fails to transmit files, or a file is rejected.
AIFMR_DQT_1010000 – Authorised Managers in ESMA Register
Validates that all authorised managers appear in ESMA’s register.
Triggers: Manager active at national level but not present in the register.
AIFMS_DQT_3010600 – Managers Reported to AIFMD System
Checks that every authorised or registered manager has submitted a report.
Triggers: Manager identifier exists in the register but no report is filed.
AIFMS_DQT_3010700 – Funds Reported to AIFMD System
Verifies that all authorised or registered funds have active submissions.
Triggers: Fund listed in register but absent from system reports.
AIFMS_DQT_3040350 – LEIs for Funds with Derivatives or MiFID Obligations
Confirms that derivative-trading or MiFID-reportable funds hold valid LEIs.
WARNING 1: Fund trades derivatives but has no LEI (required under EMIR).
WARNING 2: Fund is MiFID-reportable yet lacks an LEI.
AIFMR_DQT_4040000 – LEIs of Managers in Register
Cross-checks managers’ LEIs with GLEIF.
WARNING 1: LEI missing.
WARNING 2: LEI reported but not found or expired in GLEIF.
AIFMS_DQT_4040200 – LEIs of Managers in System
Same check within the AIFMD system.
WARNING 1: LEI missing and manager not flagged as non-reporting.
WARNING 2: LEI invalid or expired according to GLEIF.
AIFMS_DQT_4040300 – LEIs of Funds in System
Ensures every active fund has a valid LEI.
WARNING 1: LEI missing.
WARNING 2: LEI invalid or expired.
AIFMS_DQT_4040450 – Possible Available LEIs for AIFs
Looks for funds lacking an LEI but whose names match GLEIF records.
WARNING 1: Triggered when AIFIdentifierLEI is null and the fund name in ESMA equals a fund name in GLEIF with an active, non-expired LEI — meaning an LEI probably exists and should be provided.
AIFMS_DQT_3150000 – AIF Reported in EMIR but LEI Missing in AIFMD
WARNING 1: Fund appears in EMIR trade data but lacks an LEI in AIFMD filings.
AIFMS_DQT_4202000 – LEIs of Top Three Prime Brokers
WARNING 1: One or more of the top three prime brokers have no LEI recorded (except where the fund is in launch or liquidation).
AIFMS_DQT_4204000 – LEIs of Top Five Counterparties
WARNING 1: Counterparty LEI missing.
WARNING 2: Counterparty LEI missing though a counterparty is clearly listed.
AIFMS_DQT_4205000 / 4206000 – Withdrawal & Redemption Rights
Ensure investor-liquidity information is complete.
Triggers: Fields 193 and 194 (withdrawal rights and redemption frequency) empty or inconsistent.
Timeliness Tests
AIFMR_DQT_1020000 – Lag in Reporting Authorised Managers
WARNING 1: The average difference between a manager’s authorisation date and first transmission exceeds 90 days.
AIFMR_DQT_1020100 – Lag in Reporting Funds of Authorised Managers
WARNING 1: More than 90 days between a fund’s authorisation and first submission to the register.
AIFMS_DQT_1020300 – Lag in Reporting of Funds to System
WARNING 1: Average delay between reporting-period end and first valid upload exceeds 90 days.
Accuracy Tests
AIFMS_DQT_4060000 – Sum of Main Instrument Values vs AUM
WARNING 1: Total position value > AuM (over-reporting).
WARNING 2: Total position value < AuM while not all positions filled (under-reporting).
AIFMS_DQT_4060100 – Principal Exposures vs AUM
WARNING 1: Aggregated exposure > AuM.
WARNING 2: Aggregated exposure < AuM with missing exposures.
AIFMS_DQT_4060300 – Suspicious NAV Values
WARNING 1: NAV > €20 billion.
WARNING 2: NAV deviates > 5 % from NCA reference.
WARNING 3: NAV outside ECB/RIAD NAV range.
AIFMS_DQT_4060500 – Leverage Consistency Checks
Multiple warnings detect implausible leverage:
– Negative AuM or leverage values
– Leverage > AuM/NAV ratio
– Commitment method > gross method by ×3
– Values < 80 % of expected threshold, etc.
AIFMS_DQT_4130000 – Gross vs Net Performance
WARNING 1: Net performance > gross (impossible).
WARNING 2: Net = gross ≠ 0.
WARNING 3–5: Missing, zero, or outlier performance values.
AIFMS_DQT_4181000 / 4191000 / 4201000 – CS01 / DV01 / Net Delta / VaR Accuracy
Flag implausible sensitivities or missing justifications.
E.g., “WARNING 1” for suspicious CS01; “WARNING 3” when sensitivity is NA but explanation missing.
AIFMS_DQT_4203000 – Negative or Zero NAV Values
WARNING 1: NAV ≤ 0.
Consistency Tests
AIFMD_DQT_4040325 – Inconsistent LEI Between System and Register
WARNING 1: Fund LEI = Manager LEI in system (should differ).
WARNING 2: Fund LEI = Manager LEI in register.
AIFMS_DQT_3050000 – Percentages of Financing
WARNING 1: Sum of financing brackets ≠ 100 % (99–101 %).
WARNING 2: Sum < 99 % or > 101 %.
AIFMS_DQT_3100000 – Investor Concentration vs Investor Group
WARNING 1: Retail share lower than total concentration for households.
WARNING 2: Corporate retail share higher than total concentration.
WARNING 3: “Unknown/none” investor types > 20 %.
AIFMS_DQT_3110000 – Reporting Code Consistency
WARNING 1: AIF reporting code incorrect.
WARNING 2: AIFM reporting code incorrect.
WARNING 3: AIF and AIFM codes inconsistent.
AIFMS_DQT_4120000 – No-Reporting Flag Consistency
WARNING 1: Fund marked no-reporting though active.
WARNING 2: Fund no-reporting flag conflicts with manager’s last-reporting flag.
AIFMS_DQT_4140000 – Reporting Code for Leveraged Funds
WARNING 1: Reporting code claims leverage while the fund is not leveraged.
AIFMS_DQT_4170000 – Portfolio vs Investor Liquidity
WARNING 1: Portfolio-liquidity data present but investor-liquidity missing.
WARNING 2: Opposite situation (investor-liquidity present but portfolio data missing).
Statistical / Informational Tests
These provide reference metrics rather than warnings, helping NCAs monitor market trends:
- AIFMS_DQT_1090000 – Statistics of Total NAV
- AIFMS_DQT_1090100 – Statistics of Total AuM
- AIFMS_DQT_1090200 – Distribution of Leverage Ratios
- AIFMS_DQT_1180000 – Distribution of CS01 / DV01
- AIFMS_DQT_1190000 – Distribution of Net Equity, Commodity, and FX Deltas
- AIFMS_DQT_1200000 – Distribution of VaR Figures
Why This Matters
Each DQEF warning highlights a potential gap between reported data and economic reality.
Firms that integrate these checks before submission drastically cut NCA feedback cycles and demonstrate a proactive stance toward supervisory compliance.
Partnering with a provider experienced in DQEF implementation ensures that:
- LEIs, codes, and identifiers align across GLEIF, EMIR, MiFID, and ESMA systems.
- Data passes hard- and soft-checks on the first upload.
- Feedback from ESMA or NCAs is minimised, reducing reputational and operational risk.
Conclusion
The AIFMD DQEF 2025 represents a maturing regulatory ecosystem in which data quality equals regulatory trust.
Implementing these 40 tests within your reporting workflow is no longer optional—it is the backbone of compliant, efficient, and transparent fund supervision in the European Union.
