The transposition deadline for AIFMD II passed on 16 April 2026, marking a significant turning point for the European fund management industry.
As reported by Zeidler Group in its monthly update, national regulators across the European Union are now required to comply with the updated requirements set out in Directive (EU) 2024/927, which amends both the 2011 Alternative Investment Fund Managers Directive and the 2009 UCITS Directive. The revised framework, commonly referred to as AIFMD II, introduces sweeping changes to delegation arrangements, liquidity risk management, supervisory reporting, depositary and custody services, and loan origination by alternative investment funds.
Among the most consequential changes brought in by AIFMD II are those affecting the cross-border marketing of investment funds within the EU, Zeidler said.
Alternative investment fund managers marketing alternative investment funds under Articles 36 and 42 of AIFMD are now subject to enhanced disclosure obligations towards both regulators and investors under the National Private Placement Regimes.
This includes an additional disclosure requirement under Article 23 of AIFMD. Non-EU funds seeking market access into the EU also face new conditions, including an outright prohibition on funds domiciled in jurisdictions listed on the EU tax blacklist, as well as a requirement for an OECD-compliant tax information exchange agreement with the relevant EU member state. Zeidler Group has updated its Global Knowledge Hub to reflect these changes.
Separately, the Hong Kong Securities and Futures Commission (SFC) has revised its supervisory approach towards European UCITS funds offered in Hong Kong, streamlining the notification and disclosure processes for fund managers.
Under the updated framework, prior SFC approval is no longer required for certain material changes, provided those changes comply with regulatory requirements in the UCITS’ home state.
In Belgium, fund managers distributing UCITS in the market will face higher costs from this year, following a revision to the fee schedule published by the Financial Services and Markets Authority (FSMA). The UCITS notification fee per sub-fund has risen from €505 to €529, while the annual fee per sub-fund has increased from €3,452 to €3,613.
Zeidler Group notes that the pace of regulatory change across key fund distribution jurisdictions underscores the importance of investment managers maintaining a close watch on evolving requirements.
To support firms in this effort, Zeidler Group’s Global Knowledge Hub provides regularly updated regulatory overviews across more than 80 jurisdictions, maintained by a dedicated team of legal and regulatory specialists.
For more insights, read the full update here.
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