How should AIFMs report Subscriptions and Redemptions?
Subscriptions and Redemptions over the reporting period (AIF Questions 255-278)
“AIFMs should report the value of subscription and redemption orders and not the number of subscription and redemption
In older ESMA documentation it is suggested that subscriptions and redemptions should be reported in number of
subscriptions and redemptions. Later on it was made clear
(see ESMA Q&A Question 50)
that subscriptions and redemptions must be reported in Base Currency (as entered in AIF Question 49).
Relevant questions from the
ESMA AIFMD Q&A:
Question 50 [last update 9 January 2015]:
How should AIFMs report information on subscriptions and redemptions over the reporting period (questions 255 to 278 of
the consolidated reporting template)?
AIFMs should report the value of subscription and redemption orders and not the number of subscription and redemption
orders. Information should be reported for the month of the cash-flows and not for the month of the subscription and
redemption orders unless it is the same month.
For example, an AIFM is subject to quarterly reporting obligations and investors can subscribe/redeem 4 times per year
on the NAVs of 31/03, 30/06, 30/09 and 31/12 of each year. The AIFM receives for January 100 redemption orders, for
February 200 redemption orders and for March 50 redemption orders (350 redemption orders in total over the reporting
period Q1). Redemption orders are executed in April on the NAV calculated on 31 March. The NAV is €100 per share.
Therefore, the AIFM will report redemption orders for a total value of €35,000 (350*100) in April (reporting for Q2).
Question 57 [last update 12 May 2015]:
Should AIFMs consider commitments or actual capital drawdowns when they report information on subscriptions over the
reporting period for AIFs pursuing private equity strategies (questions 255 to 266 of the consolidated reporting
AIFMs should consider actual capital drawdowns and not commitments when they report information on subscriptions for
AIFs pursuing private equity strategies.
Question 61 [last update 12 May 2015]:
Should AIFMs consider distribution of dividends to
investors as redemptions for the purpose of questions 267 to 278 of the consolidated reporting
Question 74 [last update 02 December 2015]:
Is information on gross and net investment returns, change in NAV, subscriptions and redemptions mandatory or optional?
This information is mandatory for Article 24(2) AIF reporting contents but, to enable the necessary functional
flexibility, it is classified as optional from a technical standpoint. This information is optional from a technical
standpoint because AIFMs only have to report this information for the months corresponding to the reporting period for
which they report. For example, an AIFM that reports on quarterly basis will report in Q2 only information for April,
May and June and not for January, February and March. Information on January, February and March would have been part of
the report for Q1.