Regulatory Alerts2026-03-17
New European rules for liquidity management
The Dutch Authority for the Financial Markets (AFM) issued this supervisory guideline to outline the new liquidity management tool (LMT) requirements under AIFMD II, which mandate that managers of open-end funds select at least two relevant LMTs from prescribed lists and implement corresponding detailed policies by 16 April 2026. The directive requires immediate or advance reporting of LMT activations and deactivations to the AFM via a dedicated portal, while existing funds established before the deadline benefit from a one-year partial transition period solely for documenting specific LMT characteristics. Managers must ensure all selected tools and policies are integrated into offering documents and fund statutes, with automatic LMTs like suspension and side pockets excluded from the minimum count and restricted to exceptional circumstances.