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Non-EU fund managers operating in the Netherlands will be obliged to report to the Dutch AFM

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.

The AFM News states:

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 AIFMD.


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 reporting obligations.


The AIFMD reports have to be submitted in XML format.

AIFMs looking for a standalone solution for AIFMD Annex IV reporting might want to take a look at Matterhorn’s AIFMD 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 and checks consistency. Geographical, counterparty and other look-throughs will be automatically calculated for AIF and AIFM. With our AIFMD reporting software you can generate the right AIFMD reporting XML for one or more jurisdictions at the click of a button, from one data feed.

Our system is designed in such a way that all application logic and data processing is executed locally. No data will leave your premises making it extremely secure.

We are happy to send a free trial account or to arrange an online demonstration.

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