AIFMD Annex IV reporting services

AIFMD Annex IV reporting service

The AIFMD Annex IV transparency reporting requirements represent a major challenge for Alternative Investment Fund Managers (AIFM). All authorised and registered AIFMs are required to periodically report to their local regulators on each AIF they manage or market within the European Union.

Matterhorn Reporting Services offers reporting as a service for AIFMD Annex IV reporting, creating your mandatory AIFM and AIF reports while you focus on your core business.

If your firm prefers to manage the AIFMD Annex IV report process inhouse, please have a look at our software solution.


Why choose Matterhorn Reporting Services?

Our team of Regulatory Reporting specialists is very experienced and knowledgeable in managing the AIFMD Annex IV reports for a range of Alternative Investment Fund clients like Private Equity Funds, Hedge Funds, Real Estate Funds, Equity Funds, Infrastructure Funds, Patent Funds, Fund of Funds, etc.  For each fund type we know what data is required, how to classify the assets and what particular reporting elements are required. Using our reporting services will lower your AIFMD reporting cost significantly and relieves you from a laborious task.

The Matterhorn regulatory reporting team has built up in-depth knowledge of filing across Europe and the different technical filing requirements for each of the regulators.   Each year we assist many clients across the EU and Non-EU clients (who are required to file Annex IV reports in each of the countries they market their AIF) with filing across Europe.

How do we support you?

Matterhorn supports AIFs and AIFMs with:

  • Determining the reporting requirements and frequency based on factors such as leverage, assets under management (AUM) and the types of investment held.
  • Identifying and high-lighting which data is required for the AIF and AIFM reports
  • Mapping and combining available AIF and AIFM data to the required AIFMD Annex IV reporting fields
  • Classifying assets according to ESMA requirements
  • Based on our AIFMD Annex IV reporting software validate and generate all AIF and AIFM reports following a controlled process
  • Upload all AIF and AIFM reports to each regulator on behalf of the Investment Manager
  • Matterhorn can also assist clients with VAR risk calculations
  • Subsequent filings are much easier and faster after the initial setup.


Matterhorn offers transparant pricing per fund and jurisdiction.  Contact us for more information.

AIFMD Annex IV reporting obligations

Read more about AIFMD Annex IV reporting

Click to read more about the AIFMD Annex IV directive

What is AIFMD Annex IV transparancy reporting?

As part of the reporting obligations under AIFMD, all European registered alternative asset managers marketing into the EU or EEA are required by ESMA to report to their particular jurisdiction under AIFMD. Non-EU alternative fund asset managers are also required to file an AIFMD Annex IV report in all ESMA jurisdictions into which they market.

There are two ESMA AIFMD Annex IV report categories:

  • AIFM report, providing details of the manager and a consolidated view of the assets they manage
  • AIF report, has to be completed for each fund, contains details of the assets held by the fund, the risks to which it is exposed, the types of investor holding shares or interests in the fund and much more

AIFMD Third Country Passport

The AIFMD regulates the management and marketing of alternative investment funds (such as hedge funds, private equity and real estate funds) in the EU. It provides for a European ‘passport’ which allows alternative investment funds managers (AIFMs) to manage and/or market alternative investment funds (AIFs) across the European Union (EU), on the basis of a single authorization by their local regulator.

In the future the AIFMD envisages the extension of the European passport to AIFMs and AIFs from third countries, and has mandated the European Securities and Markets Authority (ESMA) to advise the European Parliament, Council and the European Commission. At this moment no Third country passports have been granted.

Non-EU / EEA (Third Country) AIFMs, for exampe Caymen Islands Hong Kong, Singapore Switzerland, the United States but also Guernsey, Jersey & Isle of Man, wishing to manage or market AIFs in the EU, and EU AIFMs marketing non-EU AIFs, do not have a European passport, so any marketing of such AIFs may only be carried out in compliance with the private placement rules of each EU country into which the AIF is sold and require regular filings of the AIFMD annex IV report to each of the regulators of the relevant EU countries.

Brexit and AIFMD Third Country Passport

Currently, UK AIFMs can manage and market EU AIFs across the EU on the basis of authorisation by the Financial Conduct Authority. However, if the UK is outside the European Economic Area post Brexit, UK AIFMs will be considered as third country AIFMs and will lose their European passport.

AIFMD Annex IV challenges

The scope of data to be completed depends on a number of factors including the assets under management (AuM), the degree of leverage, the type of assets held and whether the AIFM is registered or authorised.

AUM calculation:

For funds that hold derivatives the regulatory AUM is not the same as the NAV.  A specific calculation is needed to value the aggregate nominal value of the derivative underlying.


This is calculated as the risk exposure divided by the NAV – but there are two risk exposure calculation methods (commitment and gross)


ESMA guidelines prescribe a classification schema for portfolio assets and these need to be mapped against existing characteristics in your core systems.


Once finalized the report has to be rendered into the correct XML format required by the country’s national competent authority, and then needs to be submitted. This requires in depth technical knowledge.


Syntax and logical checks must be performed. Fund managers must make sure that they have a clear audit trail to explain, field by field, where the data originated from, how it was transformed, and if there were amendments, who did what.

The report

Compiling the report entails collecting, enriching, classifying and validating data from multiple sources and performing complex calculations. Fund managers must ensure that the reports are delivered on time and in the correct format (which will depend on the system used by the national competent authority in question).



The deadline for the first filing of the AIFMD Annex IV report is 30 days after the end of the first reporting period, once the AIFM has been authorised. In order to meet their regulatory responsibilities on time, fund managers must ensure that they have the necessary technical know-how and capabilities in place to meet the challenge of Annex IV.