Annex IV Update For Fund Managers Marketing Non-EU Funds In The Netherlands

The Dutch Authority for the Financial Markets (AFM) has announced in a newsletter published on 8th November 2022, that fund managers marketing non-EU funds in The Netherlands will need to start submitting Annex IV reports in 2023. This is a departure from the AFM’s stance to date which has been not to require the submission of Annex IV reports.

The AFM states that “notified” fund managers will be obliged to report to the AFM with effect from Q1 2023, with a deadline of 30 April 2023. It is not clear if all managers marketing non-EU funds in The Netherlands will be required to submit reports, but initial feedback from our clients indicates that the majority have already been notified. In line with other EU regulators, the submission of the reports is to be done via the AFM’s own reporting portal “AFM Portal”.

Langham Hall has been completing Annex IV reporting for non-EU AIFMs and AIFs since 2014. We prepare and file hundreds of Annex IV reports each year and are familiar with each regulator’s reporting portal. Langham Hall is able to set up the portal access for each country, and complete and file these Annex IV reports in the relevant formats required by each regulator. We file these reports directly with the regulator with minimal involvement required from the fund manager.