Last Updated on November 26, 2024 by Arnaud Collignon
Reports must be send 30 days after the end of the reporting period. (FOF + 15 days)
Reporting Dates : 31st March, 30th June, 30Th September, 31th December.
| AUM | FREQUENCY |
| 100-500M unleveraged – 1Bn | Half-yearly |
| >1Bn | Quaterly |
| Single AIF > 500M | Quaterly |
| Registered AIFM | Annualy |
1. General Procedures for Reporting Changes:
- Tables 8, 9, and 10 in Annex IV: These tables list various scenarios where AIFMs face changes in reporting frequency and explain what information must be provided in those cases.
- Initial Reporting: When an AIFM transitions to a new reporting frequency (e.g., from yearly to quarterly reporting), their first report should reflect this change. They must indicate the shift in reporting frequency by using a specific field in their report.
2. Key Scenarios and Examples:
- From Registered AIFM to Authorised AIFM with Quarterly Reporting:
- If a registered AIFM becomes authorised and shifts to quarterly reporting, they must start reporting for the full first quarter after authorisation. However, if they receive authorisation during the last quarter of the year, they continue reporting as if they were still registered (annually).
- From Quarterly to Half-Yearly Reporting:
- When an AIFM moves from quarterly reporting to half-yearly reporting, they report for the first half of the year (Q1-Q2) if the change happens in Q1, and then for the second half (Q3-Q4) afterward.
- From Authorised AIFM with Quarterly Reporting to Registered AIFM:
- If an AIFM with quarterly reporting becomes a registered AIFM with annual reporting obligations, they will only report once per year, covering the full period since their last report under the previous system.
3. Reporting Periods and Timing:
- When a change in reporting frequency happens:
- The AIFM must report for the period covering the relevant quarters or half-years, but not multiple reports for individual periods. Instead, one report should cover the full period, starting from the last report made before the change.
- For example, if an AIFM’s reporting frequency changes from quarterly to half-yearly and the change happens in Q2, they would report for H1 (covering Q1 and Q2) and then for H2 (covering Q3 and Q4).
4. Specific Reporting Cases:
- If an AIFM changes from quarterly to half-yearly reporting, they must adjust the periods they report for (e.g., from Q1-Q2, then Q3-Q4).
- When shifting from quarterly reporting back to registered AIFM with annual reporting, only the annual report needs to be filed, covering the entire period since the last report.
- From Quarterly to Annual Reporting: For example, if an AIFM transitions to annual reporting at the end of a quarter, their first report will cover the period since their last quarterly report.
5. Frequency vs. Scope of Reporting:
- In some cases, the scope of information reported remains the same, but the frequency changes. For instance, moving from half-yearly to quarterly reporting only alters how often reports are filed, not what information needs to be reported.
6. Changes Related to Non-EU AIFs:
- In cases where AIFMs manage non-EU AIFs (Alternative Investment Funds) that are marketed in the EU, the reporting frequency and scope might change based on whether the fund becomes leveraged or meets certain criteria. In some cases, AIFMs may need to start reporting more frequently or change the type of information provided, depending on the fund’s new status.
7. Reporting for AIFs with Different Thresholds:
- When the status or characteristics of the fund change (e.g., its assets under management (AuM) exceed a certain threshold), the reporting frequency and obligations may also shift. These shifts are governed by similar rules on how the first report after the change should be structured and when it should be filed.
