AIFMD II Update 1: First Edition - Daily Policy Makers (also for UCITS)

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.

1. 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.

2. 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.