Annex IV Reporting for Funds Registered for Marketing in Europe

This is a reminder that AIFMD Annex IV submissions for the period ending 31 December 2023 are due to be filed by 31 January 2024. The requirement to report is in place for:

All EU AIFMs, UK AIFMs and non-EU AIFMs which:

  1. Have active funds with commitments from EU/UK LPs marketed to under AIFMD; and
  2. Have AIFs currently being marketed under AIFMD in the EU / UK.

We have seen a marked year on year increase in GPs seeking European capital, and expect this to be the busiest filing period of the last decade. With many GPs planning to return to fundraising in 2024, we have also seen a large number of managers seeking to tidy-up any outstanding historic submissions, which may have been missed in the past.

There is no harmonised system for completing and filing these reports across the EU, rather each regulator has its own reporting portal with various nuances in reporting format and process. This reporting burden often falls to fund finance or compliance teams who may be unfamiliar with the reporting process, which will be required for all AIFs by 31st January 2024, and potentially as often as quarterly thereafter depending on the requirements.

Langham Hall has been completing Annex IV reporting for AIFMs and AIFs since 2014. We prepare and file hundreds of Annex IV reports each year and are familiar with the reporting portals across all jurisdictions. 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.