Regulatory Alerts2025-11-17
AIFMD II Update 1: First Edition - Daily Policy Makers (also for UCITS)
The Dutch Authority for the Financial Markets (AFM) issued this guide on November 17, 2025, to outline new AIFMD II requirements for alternative investment fund and UCITS managers. The regulation mandates that managers must employ at least two full-time daily policy makers who are residents of the European Union. Managers are required to promptly register these individuals with the AFM via the AFM Portal for reliability and suitability assessments to ensure compliance with the revised directive.
SUPERVISORY GUIDELINE | November 2025 1 AIFMD II Update 1 First Edition: Daily Policy Makers (also for UCITS)
In Short The revised AIFM Directive (AIFMD II) introduces new conditions for granting licenses to AIF and UCITS managers. These requirements apply to both new and existing managers. The points below concern new provisions that aim to modify the minimum composition of the management body of a manager. Existing requirements remain in full force.
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Minimum 2 full-time daily policy makers According to the new provisions, the activities of a Dutch manager of an investment undertaking or UCITS must be carried out by at least two daily policy makers who are employed full-time (minimum 36 hours per week) by the manager, or who devote themselves full-time to the execution of the manager's activities.
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Residence requirement in the European Union In addition to the above requirement, at least two full-time daily policy makers must reside in the European Union.
Register directors with the AFM in good time for the assessment of reliability and suitability It is important for managers to take measures to comply with the requirements of AIFMD II. Managers where at least two daily policy makers do not carry out activities as directors on a full-time basis and/or where at least two daily policy makers do not reside in the European Union must take measures. This may include appointing additional daily policy makers to meet legal requirements.
It is important to register daily policy makers with the AFM in good time for the assessment of reliability and suitability. This must be done via the AFM Portal. More information about the assessment of directors and statutory auditors, including costs, processing times, and other details, can be found on the AFM website.
Outlook The next publications in this series will delve deeper into specific sub-topics of the revised directive. This includes changes regarding Liquidity Management Tools (LMTs) and the new rules concerning investment undertakings that originate loans.
Keep an eye on the information on the AFM website to stay informed.
This publication was issued on 17 November 2025.