AIFMD II Six Months After Transposition: What Still Lands on 16 April 2027?

AIFMD II did not arrive in one piece. It arrived in two.

The first wave reached the rulebook in April 2026. The second, the one that changes what your regulator sees about your funds and your delegates, is six months away.

And the detailed rules that tell you exactly how to report it are only due to leave ESMA on the same day the reporting starts to apply.

That gap is the story. This piece covers what is already live, what is still coming on 16 April 2027, and what an AIFM or UCITS management company should have built before that date rather than after it.

What did 16 April 2026 actually switch on for AIFMs and UCITS management companies?

AIFMD II is Directive (EU) 2024/927. It is an amending directive: Article 1 amends the AIFMD (Directive 2011/61/EU) and Article 2 amends the UCITS Directive (Directive 2009/65/EC). It is addressed to the Member States, so it reaches firms through national law.

Article 3 sets the clock for AIFMD II transposition. Member States "shall adopt and publish, by 16 April 2026, the laws, regulations and administrative provisions necessary to comply with this Directive," and "shall apply those measures from 16 April 2026."

That date carried most of the package. Three examples from the text:

→ Liquidity management tools. An AIFM managing an open-ended AIF "shall select at least two appropriate liquidity management tools" from the Annex V list and include them in the fund rules. The amended UCITS Directive imposes the same two-tool rule on UCITS.

→ Delegation. An AIFM "shall not delegate the functions or services to the extent that, in essence, it can no longer be considered to be the manager of the AIF" and becomes "a letter-box entity." The UCITS side carries a mirror provision, plus a requirement that the management company "must be able to justify its entire delegation structure on objective reasons."

→ Loan origination. AIFMs managing loan-originating AIFs face a closed-ended default ("An AIFM shall ensure that the loan-originating AIF it manages is closed-ended"), a single-borrower concentration limit, and a duty to retain "5 % of the notional value of each loan that the AIF has originated and subsequently transferred to third parties."

We will not tell you which Member States have their national measures in force. Check your home regulator. What the Directive itself fixes is the dates, and those are not in dispute.

Which AIFMD II measures did Article 3 hold back until 16 April 2027?

Article 3 carves out two items. Member States apply everything from 16 April 2026 "with the exception of the measures transposing Article 1(12), and those transposing Article 2(7) with regard to Article 20a of Directive 2009/65/EC, which they shall apply from 16 April 2027."

Both carve-outs are about supervisory reporting.

Article 1(12) rewrites AIFMD Article 24. The new paragraph 1 requires an AIFM to "regularly report to the competent authorities of its home Member State on the markets and instruments in which it trades on behalf of the AIFs it manages." The report must "include the identifiers that are necessary to connect the data provided on assets, AIFs and AIFMs to other supervisory or publicly available data sources."

The rewritten Article 24(2) then adds:

• The AIF's "current risk profile," including market, liquidity, counterparty and operational risk, and "the total amount of leverage employed."
• A full delegation disclosure: who the delegates are, whether they have close links, the full-time equivalent staff doing portfolio and risk management in-house, the share of assets under delegated portfolio management, the staff monitoring the delegates, and "the number and dates of the periodic due diligence reviews carried out by the AIFM to monitor the delegated activity, a list of issues identified."
• Sub-delegation details and "the commencement and expiry dates of the delegation and sub-delegation arrangements."
• "the list of Member States in which the units or shares of the AIF are actually marketed."

Article 2(7) inserts UCITS Article 20a. Under it, a UCITS management company "shall regularly report to the competent authorities of the UCITS home Member State on the markets and instruments in which it trades on behalf of UCITS it manages."

Article 20a(2) lists what goes in: the liquidity arrangements "including the current selection of liquidity management tools, and any activation or deactivation thereof," the risk profile and leverage, "the results of the stress tests performed in accordance with Article 51(1)," the same eight-point delegation disclosure the AIFM side gets, and the marketing Member States.

Read those lists together and the design is plain. The rules on liquidity tools and delegation went live in 2026. The reporting that lets supervisors check those rules goes live in 2027.

Why is 16 April 2027 also the date ESMA's RTS and ITS are due, and what does that mean for your build?

Here is the awkward part.

Both reporting articles hand the detail to ESMA. For AIFMs, new Article 24(5a) tells ESMA to develop draft ESMA regulatory technical standards specifying "the details of the information to be reported," "the appropriate level of standardisation" of the delegation data, and "the reporting frequency and timing." Article 24(5b) adds draft implementing technical standards on "the format and data standards," the identifiers, and "the methods and arrangements for submitting the reports."

UCITS Article 20a(5) and (6) repeat the structure for management companies.

The deadline in all four places is the same: "ESMA shall submit those draft regulatory technical standards to the Commission by 16 April 2027." The ITS paragraphs say the same.

That is a submission deadline, not an application date. After submission, the Directive gives the Commission power to adopt the RTS "in accordance with Articles 10 to 14 of Regulation (EU) No 1095/2010" and the ITS under Article 15. The Directive itself does not fix when that adoption happens or when the standards begin to apply.

So on 16 April 2027 you have national measures applying a reporting obligation, and draft technical standards on their way to Brussels. The frequency, the field-level detail and the file format may not be settled law on that date.

What that means for your build:

• Do not wait for the template to start collecting. The categories of data are already fixed in the Directive text. The template only decides how they are shaped.
• Do not overbuild to a guessed format. Hard-coding a schema now risks a rework once the ITS land.
• Do watch one constraint. On delegation data, ESMA "shall not introduce reporting obligations in addition to those set out in paragraph 2, point (d)." The eight delegation points in the Directive are the ceiling for that block. You can plan to them.

What should an AIFM or UCITS ManCo have running before the second wave, not after?

The second wave is a data problem dressed as a reporting problem. Each line in Article 24(2) and Article 20a(2) needs an owner and a source system. Six months is enough time to find them, not to invent them.

A practical sequence:

→ Delegation register. One record per delegate and sub-delegate: name, domicile, close links, authorisation status, supervisor, identifier, activities delegated, share of assets, start and expiry dates. Many firms hold this across contracts, an outsourcing log and someone's spreadsheet. The Directive now asks for it in one place.

→ Oversight evidence. The text asks for the number and dates of due diligence reviews, the issues found, the measures adopted and their target dates. If your oversight reviews live in meeting minutes, they are not reportable yet. This is where the gap usually shows. It is also where third-party risk work pays off twice.

→ FTE counts. Two numbers: staff doing day-to-day portfolio and risk management in-house, and staff monitoring delegates. Decide now how you count them, so the number is reproducible.

→ Liquidity tool log. For UCITS, the current tool selection "and any activation or deactivation thereof." You selected the tools in wave one. Now every activation needs a timestamp.

→ Stress test outputs. For UCITS, the results under Article 51(1). Make sure they are stored as data, not only as a board pack PDF.

→ Marketing footprint. The Member States where units are "actually marketed," including by distributors acting for you. Reconcile that list against your distribution agreements and passport notifications.

→ Identifiers. The text repeatedly asks for identifiers that connect your data to "other supervisory or publicly available data sources." Map your fund, asset and delegate identifiers now.

How do you keep one evidence trail across AIFMD II and UCITS instead of two?

If you run both AIFs and UCITS, look at the two lists side by side. The delegation block in Article 24(2)(d) and the one in Article 20a(2)(d) are word-for-word parallel, eight points each. Risk profile and leverage match. Marketing Member States match.

The trap is building two pipelines because two directives are involved. That doubles the reconciliation work and guarantees the two returns will one day disagree about the same delegate.

The better structure is one fact, many uses. A delegate's due diligence review is recorded once, with its date and its findings, and both returns draw from it. The same record supports your risk management reporting to the board and your DORA third-party register where that applies.

This is how Aigis GRC handles it. Each obligation is traced to a verbatim quote from the legal text, so the AIFMD Article 24 line and the UCITS Article 20a line both point to the same underlying control and the same evidence. Answer once. Assess everything. When the ESMA standards are adopted, the change lands as a clause-level diff against the obligations you already hold, not a new project. The platform maps that across 295+ regulations in 34 jurisdictions, source-grounded rather than generated.

What is the 2029 review horizon, and should it change anything you do now?

The Directive builds in a review. New AIFMD Article 69-a says: "By 16 April 2029 and following the report produced by ESMA in accordance with Article 7(8), the Commission shall initiate a review of the functioning of the rules laid down in this Directive." The amended UCITS Directive has a parallel review in new Article 110a.

The AIFMD review list includes "the effectiveness of the AIFM authorisation requirements in Articles 7 and 8 as regards the delegation regime laid down in Article 20 of this Directive, in particular with regard to preventing the creation of letter-box entities in the Union."

That is a Commission obligation, not yours. But note what the review will run on. On the UCITS side, ESMA's own 2029 report on delegation is to be "based, inter alia, on the data reported to the competent authorities in accordance with Article 20a(2), point (d)."

In plain terms: the delegation data you start reporting in 2027 is the evidence base for the next round of delegation policy. Clean, consistent reporting is a compliance task now and an input to the rules later.

FAQ: AIFMD II 2027 deadlines

Does all of AIFMD II apply from 16 April 2027? No. Under Article 3, Member States apply the transposing measures from 16 April 2026. The exceptions are the measures transposing Article 1(12) (AIFMD Article 24 reporting) and Article 2(7) as regards UCITS Article 20a (management company reporting), which apply from 16 April 2027.

Do ESMA's reporting standards apply on 16 April 2027? The Directive says ESMA "shall submit" the draft RTS and ITS to the Commission by 16 April 2027. That is a submission deadline. Adoption by the Commission comes after, and the Directive does not set a date for it.

Is a UCITS management company now subject to regular supervisory reporting? Yes, from 16 April 2027 under national measures transposing new UCITS Article 20a. It covers markets and instruments traded, liquidity management tools and their activation, risk profile and leverage, stress test results, delegation arrangements and marketing Member States.

What were ESMA's 16 April 2026 deadlines? ESMA deadlines included guidelines on when an AIF or UCITS name is "unfair, unclear or misleading," guidelines for competent authorities on supervisory powers, and a report on the integrated collection of supervisory data. These were obligations on ESMA, not on firms.

Six months is enough to put every line of the 2027 return on a named source. See how the obligations map to your own fund range at agrc.ai.