The European fund management landscape shifted materially on 16 April 2026, when the transposition deadline for AIFMD II expired.
According to Zeidler Group in its monthly update, national regulators across the EU must now comply with the requirements introduced by Directive (EU) 2024/927, which amends both the Alternative Investment Fund Managers Directive of 2011 and the UCITS Directive of 2009.
The updated rules touch on a broad range of areas, including delegation arrangements, liquidity risk management, supervisory reporting, depositary and custody services, and loan origination by alternative investment funds.
The cross-border marketing of investment funds is among the areas most directly affected by the new framework, Zeidler said.
Alternative investment fund managers marketing alternative investment funds into the EU under Articles 36 and 42 of AIFMD must now meet strengthened disclosure obligations to both regulators and investors under the National Private Placement Regimes, including an additional disclosure requirement introduced under Article 23 of AIFMD.
Non-EU funds seeking access to European markets are also subject to tighter conditions. These include a ban on funds domiciled in jurisdictions that appear on the EU tax blacklist, alongside a requirement for an OECD-compliant tax information exchange agreement with the relevant member state.
On the other side of the world, Hong Kong’s Securities and Futures Commission has taken steps to ease the administrative burden on European UCITS funds distributed in the city. Under its revised supervisory approach, fund managers no longer need to seek prior SFC approval for certain material changes, provided those changes satisfy the regulatory requirements of the UCITS’ home state.
Belgian fund managers, meanwhile, will need to absorb higher regulatory costs this year. The country’s Financial Services and Markets Authority has published a revised fee schedule for 2026, lifting the UCITS notification fee per sub-fund from €505 to €529 and increasing the annual fee per sub-fund from €3,452 to €3,613.
Zeidler Group emphasises that investment managers must remain alert to shifting requirements across jurisdictions in order to maintain compliance, manage rising costs, and keep cross-border distribution strategies on track. The firm’s Global Knowledge Hub, which spans more than 80 jurisdictions and is continuously maintained by legal and regulatory specialists, is designed to help firms do precisely that.
For more insights, read the full update here.
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