AIFMD reporting

Regulatory reporting is a growing burden and regulators continue to take disciplinary action against firms for missing filings or reporting incorrect data. We have reporting specialists in the UKUS and Asia that can help with anything from Annex IV under AIFMD to Form PF, Form 13F and Form CPO-PQR. Our team can help with all elements of completing your returns, from breaking down methodologies and calculating portfolio responses to making the final submission directly to the relevant regulator on your behalf.

AIFMD reporting: Annex IV

Meeting the challenging reporting requirements of AIFMD Annex IV means significant investment in software and skills. Figuring out how and what you need to report under AIFMD is complex and depends on your structure and assets under management.

Most AIFMs who are managing or marketing AIFs into the European Union or EEA will have to complete Annex IV reports. These Annex IV reports will have to be submitted to the relevant National Competent Authority (NCA), which in the UK is the FCA. A non-EEA AIFM will have to file a report to the NCA of each member state in which they market an AIF. Firms are required to make returns either quarterly, bi-annually or annually.

Annex IV returns can require complex risk calculations and all returns need to be submitted to the FCA in a special XML formatted file. We can help you with the completion of these returns and have all the software needed to file the reports on your behalf in multiple jurisdictions.

AIFMD Annex IV reporting in the UK

All authorised and registered UK AIFMs are required to submit their annual Annex IV transparency report to the FCA by 31st January 2019. Non-EU AIFMS, or EU AIFMs marketing into additional EU jurisdictions will also have to file Annex IV reports with national competent authorities.

Annex IV Reporting deadlines 2018 – 2019

Reporting Period
FCA Filing Deadline
Q4 / HY2 / Y Oct 1st – Dec 31st 2019 January 31st 2019
Q1 Jan 1st – March 31st 2019 April 30th 2019
Q2 / HY1 April 1st – June 30th 2019 July 31st 2019
Q3 July 1st – September 30th 2019 October 31st 2019
Q4 / HY2 / Y October 1st – December 31st 2019 January 31st 2020

Q = Quarterly filers HY1/HY2 = Bi-annual filers Y = Annual filers

AIFMD Annex IV reporting in Luxembourg

Submitting Annex IV reports to Luxembourg can be a real challenge. The reports must be sent exclusively using a complex ‘channel’ infrastructure as required by Luxembourg’s Commission de Surveillance du Secteur Financier (CSSF). The reporting also has to be made in XML format, which must be compliant with the most recent format – or XSD – published by ESMA.

For many of our clients, we work directly with the CSSF in Luxembourg to access the SoFIE reporting platform. As well as support on an ongoing basis with the reporting requirements, Bovill offers a unique service in helping firms gain access approval to the CSSFs reporting platforms. We do this by obtaining a LuxTrust certificate, in the name of the client, from a CSSF approved entity. Holding the certificate means we can encrypt and transmit the XMLs, therefore becoming the technical submitters for all AIF001 & AIF002 reports in Luxembourg.

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