Non-EU fund managers operating in the Netherlands will be obliged to report to the Dutch AFM
On 8 November 2022, the Dutch Authority for the Financial Markets (AFM) published the requirement for non-EU (“third
country”) fund managers operating in the Netherlands to submit AIFMD reports with effect from Q1 2023.
Non-EU fund managers:
Notified fund managers and funds established outside the EU will be obliged to report to the AFM with effect
from Q1 2023. These non-EU fund managers will be obliged to submit their first reports in April 2023. This concerns fund
managers and funds with a notification under Section 1:13b(1) and (2) or Section 2:66 of the
Dutch Financial Supervision Act
(Wet op het financieel toezicht, Wft), as well as notifications under Article 36 or 42 of the
Non-EU fund managers will not be subject to the DQEF review in 2023, but they will be subject to this review from 2024.
Reporting via the AFM Portal:
The AFM urges all fund managers established in countries outside the EU to create an AFM Portal account with access to
Reporting in the near future, in order to prevent undesirable delays in reporting, and to enable the AFM to email them
updates. Click for
more information on creating an AFM Portal account,
to learn more about
submitting reports via the AFM Portal,
and for the AIFMD
The AIFMD reports have to be submitted in XML format.
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reporting software. We offer an Annex IV reporting template that includes a comprehensive description of what
information is required in each field. Our software application validates the client’s data against ESMA requirements
checks consistency. Geographical, counterparty and other look-throughs will be automatically calculated for AIF and
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We are happy to send a free trial account or to arrange
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