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Malta MFSA : AIFM Reporting Guidelines

Last Updated on August 14, 2025 by Arnaud Collignon

1. Executive Summary

The MFSA’s “Reporting Guidelines for Alternative Investment Fund Managers” outlines the mandatory reporting obligations for AIFMs operating in Malta, as mandated by the Alternative Investment Fund Managers Directive (AIFMD). AIFMs are required to submit regular information about themselves and the Alternative Investment Funds (AIFs) they manage or market within the EU. Reporting is primarily done through the MFSA’s Licence Holder Portal (LH Portal) using XML format for Annex IV Returns and a spreadsheet for Annex 5 Returns. The frequency and specific content of reports depend on factors such as Assets Under Management (AUM), leverage employed, and the AIFM’s license status (full-scope, de minimis, or self-managed). Compliance with these guidelines is crucial to avoid regulatory actions.

2. Key Reporting Requirements and Submissions

2.1. Annex IV Returns (XML Format)

  • Mandate: AIFMs are required to submit complete Annex IV Returns (Annexes 1-4 as applicable) to the MFSA, which then transmits this information to the European Securities and Markets Authority (ESMA). This is in accordance with Articles 3 and 24 of the AIFMD.
  • Applicability:Full AIFMs: Annexes 1 to 4.
  • De-Minimis AIFMs: Annexes 1 and 2.
  • Self-Managed PIFs: Annexes 1 and 2.
  • Self-Managed AIFs: Annexes 1 to 4.
  • Information Content:De minimis Category 2 AIFMs: Report on the entity itself and AIFs under management (Annexes 1 and 2).
  • Self-Managed PIFs and AIFs: Submit aggregated data on sub-funds/compartments in a DATMAN file and a separate DATAIF file for each sub-fund/compartment.
  • Above-threshold AIFMs: Submit information prescribed in Article 24(2) AIFMD for all AIFs under management, and Article 24(4) AIFMD for AIFs employing leverage on a substantial basis (Annexes 3 and 4).
  • ESMA Opinion (ESMA/2013/1340): AIFMs subject to quarterly or half-yearly reporting must also submit additional information for systemic risk monitoring, including:
  • “Information on high frequency trading, including the total number of transactions and the corresponding market value of buys and sells over the reporting period.”
  • “Whether a short position is used to hedge a position with similar exposure and, if so, the extent of the hedging expressed as a percentage of the position hedged.”
  • “A geographical breakdown of the AIF’s investments.”
  • “Information on risk measures including vega exposure, value-at-risk, net FX delta as well as net commodity delta.”
  • “Information on non-EU master AIFs not marketed in the EU.”
  • Format: Submissions must be in Extensible Mark-up Language (XML) format, as defined by ESMA. The ZIP files should contain an AIFM file (AIFMD_DATMAN_V1.2.xsd) and one or more AIF files (AIFMD_DATAIF_V1.2.xsd).

Looking for a solution to generate MFSA XML compliant AIFMD reports?

AIFMD Annex IV – 2 solutions for Efficient Reporting
  • Specific Information Reporting:Reporting Member State Code: MT for returns to the MFSA.
  • AIFM National Code: ISXXXXX (MFSA license number without punctuation). For non-Maltese AIFMs, the license number from their home competent authority.
  • AIF National Code: CISXXXA (MFSA license number without punctuation). For non-Maltese AIFs, the license number from their home competent authority. Notified AIFs (NAIFs) use their Registry Of Companies (ROC) entity ID, with sub-funds appending a letter (e.g., SV456A).
  • Crucial Note: “If National Codes are not filled in correctly as described above, the returns will be rejected.”
  • Special Situations:Limited or No Data: AIFMs must submit a “nil return” by setting “AIFM no reporting flag” to ‘True’ and leaving other data empty. For licensed AIFs that haven’t commenced operations, an AIF nil return file is required, with data point 23 set to ‘True’.
  • Change in NAV: If the final NAV is unavailable by the deadline, an estimated NAV can be used. Discrepancies between estimated and official NAV require updated Annex IV and Annex 5 Returns, with AMND in the FilingType field for Annex IV.
  • Share Classes in Different Currencies: Each share class should be disclosed separately. AIFs with different currency share classes must choose one base currency for reporting.
  • Leverage: AIFMs managing AIFs employing “leverage on a substantial basis” must report additional information, including the overall leverage level, breakdown of leverage sources, asset re-use under leveraging, and identity of the five largest sources of borrowed cash/securities.
  • Submission Platform: All Annex IV Returns must be submitted through the MFSA’s Licence Holder (LH) Portal (https://lhportal.mfsa.com.mt/).
  • File Naming Convention: LICENCEHOLDERCODE_MMMYYYY_AIFM.zip (e.g., ABCL_Dec2018_AIFM.zip). The ZIP file must contain the XML files.
  • Validation: The LH Portal validates files against ESMA’s XSD Schema and checks file names. Rejected files require amendment and resubmission.

2.2. Annex 5 Returns (Spreadsheet Format)

  • Mandate: Required for full scope AIFMs and de minimis Category 2 AIFMs. Self-managed PIFs and self-managed AIFs are excluded.
  • Content: A spreadsheet including information on AIFs under management: “the name, national code, inception date, management status, assets under management and domicile of the AIF as well as the jurisdiction in which the AIF is marketed (where applicable).”
  • Format: Spreadsheet, submitted as a Zipped File.
  • Submission Platform: Through the MFSA’s LH Portal.
  • File Naming Convention: LHCode_MonthYear_ANNEX5.zip (e.g., ABCL_Jun2018_ANNEX5.zip). The spreadsheet inside the zip should be named LHCode_MonthYear_ANNEX5.
  • Validation: “No validation checks will be conducted on Annex 5 Returns.” The LH Portal status will simply be ‘File uploaded to MFSA’.

3. Reporting Timelines and Frequency

Reporting frequency is determined by the AIFM’s license status and Assets Under Management (AUM), calculated according to Article 2 AIFMR.

3.1. Annex IV Returns Reporting Frequency

  • Assets Under Management (AUM)Frequency of ReportingLess than EUR 100 million (De minimis or Full AIFM)AnnualLess than EUR 500 million unleveraged with five-year lock-up period (De minimis or Full AIFM)AnnualGreater than EUR 100 million and less than EUR 1 billion (AIFM)Half-yearlyGreater than EUR 500 million unleveraged with five-year lock-up period and less than EUR 1 billion (AIFM)Half-yearlyGreater than EUR 1 billion (AIFM)QuarterlyAIFs greater than EUR 500 million (Specific AIF Reporting)QuarterlyUnleveraged AIF investing in non-listed companies and issuers in order to acquire controlAnnualNote on Leverage: If any individual AIF under half-yearly reporting obligations has leveraged assets and AUM exceeding EUR 500 million, the AIFM must report quarterly for that particular AIF.
  • Fund of Funds: AIFMs managing fund of funds are allowed an additional 15-day period for Annex IV Returns, requiring formal notification to the MFSA.

3.2. Annex 5 Returns Reporting Frequency

AIFM TypeReporting FrequencyFull scope AIFMsQuarterlyDe minimis Category 2 AIFMsHalf-yearly3.3. General Reporting Period Deadlines

  • All reports must be submitted to the MFSA within one month from the end of the reporting period.
  • If the deadline falls on a weekend or public holiday, submission is due on the following working day.
  • Annual Reporting (as at 31 December): By January 31st of the following year.
  • Semi-annual Reporting (as at 30 June and 31 December): By July 31st and January 31st respectively.
  • Quarterly Reporting (as at 31 March, 30 June, 30 September, 31 December): By April 30th, July 31st, October 31st, and January 31st respectively.

3.4. First Reporting Period

  • AIFMs must report for the first full quarter following their license issue date. The same applies to the first reporting of an AIF.
  • Example: “AIFM licensed in Quarter 3 of 2018 – subject to annual reporting: The AIFM shall submit the first report covering the period from 1 October to 31 December 2018.”

3.5. Liquidation/Merger

  • The AIFM’s last report for an AIF must be provided to the MFSA immediately following the AIF’s liquidation or merger, or “not later than one month after the end of the quarter in which the AIF has been liquidated or put into liquidation.” The ‘Last Reporting Flag’ should be marked as ‘Yes’.

3.6. Change in Reporting Frequency

  • AIFMs must adhere to new reporting obligations as indicated in Appendix B of the guidelines in case of a shift in reporting frequency.
  • “It is the responsibility of AIFMs to notify the MFSA of any changes in relation to AIFs managed or marketed prior to the due date of the returns.”

4. MFSA Licence Holder (LH) Portal

  • Access: https://lhportal.mfsa.com.mt/.
  • Account Setup: Prospective users must submit the LH Portal Registration Form (Appendix D) to .
  • First-time users will receive a username and temporary password, requiring a reset upon first login.
  • Security: “Only reporting files submitted by the IP address/es which would have been originally registered will be accepted by the MFSA for the specific AIFM.” Additional users require written confirmation from the Compliance Officer.
  • Functionality: Allows users to upload files, monitor submission history, and track status.
  • Submission Statuses: Users can view various statuses, including ‘File uploaded to MFSA’, ‘File pending xml validation’, ‘XML is valid/invalid’, ‘File accepted/rejected by ESA’, and ‘Incorrect filename submitted’.
  • Feedback: The LH Portal sends automated email confirmations for accepted or rejected files. Rejected files require amendment and timely resubmission. Users must regularly check the status of uploaded files.
  • No Password Protection: “Licence Holders shall not password-protect any documents that are being submitted through the MFSA LH Portal.”

5. Further Considerations

  • Accuracy: AIFMs must ensure data provided in all forms is “complete and accurate.”
  • Consequences of Non-Compliance: “Late submissions of returns may trigger regulatory actions on AIFMs in accordance with Article 16A of the Investment Services Act, 1994.” Incorrect returns will require resubmission.
  • Mixed Frequencies: An AIFM may need to report its own data and AIF data at different frequencies (e.g., a half-yearly AIFM reporting quarterly for a large leveraged AIF).
  • Related Documentation: These guidelines should be read in conjunction with other MFSA circulars (March 2014, December 2014, May 2018), FAQs, and relevant Appendices of the Investment Services Rules, as well as European documents such as the AIFMD, Delegated Regulation 231/2013, and various ESMA guidelines and technical guidance.