Last Updated on July 18, 2025 by Arnaud Collignon
I. Introduction and Scope
This guidance is crucial for all AIFMs, including Internally Managed Alternative Investment Funds (AIFs), authorized or registered by the CBI, or those managing/marketing AIFs in Ireland. Its primary aim is to inform AIFMs about the reporting requirements for AIFMD Reporting Returns, specifically the Alternative Investment Fund Manager Return and the Alternative Investment Fund Return.
- Key Acronyms:
- AIFMD: Alternative Investment Fund Manager Directive
- AIFM: Alternative Investment Fund Manager
- AIF: Alternative Investment Fund
- ESMA: European Securities and Markets Authority
- CBI: Central Bank of Ireland
- Portal: Central Bank of Ireland Portal
- Complementary Documents: This guidance must be used in conjunction with the Central Bank Portal User Manual, the CBI’s AIF Rulebook, and ESMA guidance documents (all linked in Appendix 2 of the original source).
II. Core Reporting Obligations & Principles
AIFMs have a dual reporting obligation to the Central Bank:
- AIFMD Reporting (for ESMA transmission): AIFMs must submit information detailed in Article 3(3)(d) and 24(1), (2), and (4) of the AIFMD for onward transmission to ESMA.
- Prudential Reporting (CBI Mandate): AIFMs authorized by the CBI have additional prudential reporting obligations as mandated in the CBI’s AIF Rulebook.
Crucial Responsibilities of AIFMs:
- Accuracy and Completeness: AIFMs should take care to ensure that the data provided in a return form is accurate and complete. AIFMs will be required to resubmit incorrect returns. AIFMs submitting incorrect or late returns may be subject to further action.
- Timeliness: Returns must be successfully submitted and signed-off by the deadline. Failure to do so means failing to meet reporting obligations. AIFMs should allow sufficient time for validation and sign-off.
- Determining Obligation & Frequency: It is the AIFM’s responsibility to determine its own reporting obligation and that of its AIFs under management, including reporting frequency, in line with AIFMD (referencing ESMA’s Decision Trees).
- No Password Protection: Users should not password-protect any document that is being submitted to the Central Bank as part of a return. Password-protected documents cannot be accepted through the Portal.
III. Reporting Mechanics: What, How, and When
A. What Must Be Submitted:
- AIFM Return: One return specific to the AIFM.
- AIF Return(s): A separate return for each AIF that the AIFM is required to report on.
- Varying Frequencies: AIFMs may need to report their own data at a different frequency to the AIFs under their management. Similarly, AIFs under the same management may have different reporting frequencies. Changes in AIF characteristics (AUM, leverage, investments in non-listed companies) can alter reporting frequency, requiring adherence to ESMA guidance.
- Non-EU Master AIFs: The CBI requires information for non-EU master AIFs not marketed in the EU but having EU feeder AIFs or non-EU feeder AIFs marketed in the Union under Article 42. This necessitates a separate AIF file and an AIF National Code (i.e. C-code) obtained from .
B. Format of Returns:
- XML File Upload: Reporting under AIFMD is exclusively via XML file upload to the CBI Portal.
- ESMA Compatibility: XML returns must be compatible with the ESMA XSD schema. AIFMs are encouraged to validate their XML files against the ESMA XSD schema before submission.
- Multiple AIF Returns in One File: Multiple AIF returns can be contained in the one XML file.
- Specific XML Headers: Precise XML headers are required for both AIFM and AIF files (examples provided in the source document).
- C-Code Requirement: The AIFM National Code and AIF National Code fields must be populated with the Central Bank’s institution reference code (C-code or Fund Number) in the format C999100. Incorrect formatting will lead to rejections.
C. Submission Deadlines:
- General Rule: Returns must be submitted by the last calendar day of the month following the quarter end. (e.g., September 30th reporting date, October 31st deadline).
- Fund of Funds Extension: For AIFs that are a Fund of Funds, this period may be extended by 15 days.
D. Filing a ‘Nil’ Return:
- If no information is available to report (e.g., new AIFM awaiting activity, new AIF awaiting first investments), AIFMs must still provide a return by using a specific no reporting flag.
- AIFM File: Data points 1-21 must be completed, and data point 21 (AIFM no reporting flag) set to ‘T’. All other data points must be empty.
- AIF File: Data points 1-23 must be completed, and data point 23 (AIF No Reporting Flag) set to ‘T’. All other data points must be empty.
E. Firms Not Required to Report:
- A Non-EU AIFM marketing an AIF into Ireland under Regulation 43 is not required to report if they have notified the CBI that marketing has ceased or will not commence, and confirm no Irish investors are in the AIF. A new notification is required before marketing can resume to Irish investors.
IV. Submission Procedure via the CBI Portal
The submission process involves several key steps:
- Log On: Access the Portal using provided credentials.
- Navigate to Returns: Click “Returns” then “View/Edit Returns”.
- Create Return Instance: A return instance must be created before a file can be uploaded. Click “Add Return” and select the “Reporting Date” (e.g., March 31, June 30, etc.) and “Submission Due Date” (e.g., April 30, July 31, etc.).
- For AIF returns, select the relevant AIF C-code(s) (multiple can be selected by holding Ctrl). If a C-code is missing, contact the CBI.
- Load File: Click “Load a File,” then “Choose File” to select the XML file from its location.
- Naming Convention: The file name must follow specific conventions:
- AIFM: C999100_YYYYMMDD_AIM.xml (e.g., C999100_20280630_AIM.xml)
- AIF (Single or Multiple): C999100_YYYYMMDD_AIF.xml (e.g., C999100_20280630_AIF.xml)
- Ensure the file is not open on the desktop.
- Validation: The file will undergo validation. The user will receive an email regarding success or failure. Validation errors are viewable on the Portal (refer to “AIFMD Reporting – List of CAF and CAM errors”).
- Correction and Resubmission: Correct any validation errors and resubmit the file.
- Finalize: Once accepted, the return must be finalized by clicking “Finalise” within the return screen.
- Sign-Off: A different person than the one who finalized the return must sign it off.
V. Validation and Common Issues
A. Validation Checks:
- All fields are validated against ESMA AIFMD reporting IT technical guidance.
- Additional CBI Checks:Return periods must be within one year and not cross a year-end.
- Cross-check of AIFs against CBI’s internal systems. If an AIF is not authorized/notified/registered with the CBI, submission will be prevented.
- AIFM Responsibility for Changes: It is the responsibility of the AIFM to ensure that the Central Bank is notified of any changes with respect to the AIFs being managed or marketed by the AIFM prior to the returns being due.
B. Common Issues Identified:
- AIF C-code not appearing: Usually indicates the AIF is not linked to the AIFM on CBI systems. Contact the CBI to rectify.
- Incorrect XML Header: Files will not process successfully if the precise XML headers specified in the guidance are not used.
VI. Important Contacts & Resources
- Email for Support: (for general queries not covered by guidance notes, or to receive an AIF National Code for non-EU master AIFs).
- Email for Manager-Fund Relationship Changes: Various specific email addresses are provided in Appendix 1 for notifications regarding seeking/ceasing to manage or market AIFs (e.g., , , ).
- Useful Links (Appendix 2): Comprehensive links to the CBI Portal, AIFM Reporting Requirements, AIF Rulebook, AIFMD Reporting Date Matrix, ESMA website for AIFMD guidance, ESMA AIFMD reporting IT technical guidance, ESMA Guidance Document (including Decision Trees), and the Full list of CAF and CAM errors.
