Regulatory Framework

AIFMD Advisory

Comprehensive AIFMD implementation — from initial licence application through ongoing compliance management. We cover the full lifecycle of the Alternative Investment Fund Managers Directive, including preparation for AIFMD II changes effective April 2026.

Applicable to: Hedge funds, private equity, real estate funds, fund-of-funds, and other alternative investment structures

What we do

The Alternative Investment Fund Managers Directive is the cornerstone regulatory framework for managers of non-UCITS funds in Europe. It covers authorisation, operating conditions, delegation, depositary requirements, leverage limits, transparency, and cross-border marketing — a broad and technically demanding regime.

Diletti has deep experience with AIFMD implementation for Dutch-based managers. We have supported AFM licence applications, designed risk management frameworks that satisfy both the letter and spirit of the regulation, structured depositary arrangements, and built Annex IV reporting pipelines. Our experience spans hedge funds, private equity, real estate, and fund-of-funds structures.

With AIFMD II entering into force in April 2026, managers face significant new requirements around liquidity management tools, loan-originating funds, delegation oversight, and reporting. We help you assess the impact and prepare your compliance infrastructure ahead of the deadline.

Core capabilities

AIFMD Licence Applications

Full AFM authorisation support — programme of operations, organisational structure, initial capital and own funds calculations, fit-and-proper documentation, and regulatory dialogue management with AFM and DNB.

Risk Management Policy

AIFMD-compliant risk management framework covering market risk (VaR, stress testing), credit risk, liquidity risk, counterparty risk, and operational risk. Includes risk limits, escalation procedures, and board reporting.

Depositary & Custody

Depositary selection and arrangement structuring, safekeeping duties, cash flow monitoring, oversight obligations, and liability framework. Includes prime brokerage tri-party arrangements.

Annex IV Reporting

End-to-end Annex IV reporting setup — data sourcing, field mapping, XML generation, validation, and filing with AFM. Covers fund-level and manager-level reports on quarterly and annual cycles.

Delegation & Outsourcing

Delegation arrangements for portfolio management, risk management, and operational functions. Substance requirements, oversight frameworks, and ESMA guidelines on delegation compliance.

AIFMD II Preparation

Gap analysis against AIFMD II requirements — liquidity management tools (LMTs), loan-originating fund rules, enhanced delegation reporting, and updated Annex IV fields. Transition planning for April 2026 deadline.

Relevant templates

EMIR Refit Reporting Pack

Derivative reporting framework relevant for AIFM derivative usage. View template →

MiFID II Compliance Manual

Compliance framework with significant overlap for AIFM top-up permissions (MiFID services). View template →

Track record

Diletti brings decades of asset management experience, having worked inside ING Investment Management, Aegon Asset Management, Robeco, and MN Services on risk management, performance measurement, and regulatory implementation. This first-hand operational experience means we understand not just what AIFMD requires, but how to implement it in a way that works for your investment process and operations.

Need AIFMD guidance?

Whether you are applying for a licence, preparing for AIFMD II, or optimising your existing compliance framework — a short call will clarify your next steps.

Schedule a Call