AIFMD 2 in practice: A cross‑border implementation guide

Targeted change with meaningful operational consequences for European fund managers.

AIFMD 2 introduces a series of focused amendments to the alternative investment framework which, taken together, will have a meaningful impact on how managers structure products, organise operations and operate across European markets.

Applying from 16 April 2026, the Directive addresses defined areas including loan origination, liquidity management tools, delegation and governance, reporting and transparency, marketing, management company activities and depositary services. While the changes are specific in scope and do not amount to a structural reform of AIFMD, they increase the operational intensity of the regime and require managers to reassess systems, documentation and internal frameworks.

A key development is the introduction of product‑level rules, notably for loan‑originating AIFs, alongside more formalised liquidity management and expanded reporting and disclosure obligations. Implementation, however, takes place against a fragmented transposition landscape, with differences across jurisdictions expected to persist.

What’s covered

This guide provides practical insight into how AIFMD 2 operates in practice, with perspectives from France, Germany, Ireland, Italy, Luxembourg and Spain, and a comparison with the UK framework.

It examines:

• The new EU loan‑origination regime and its implications for fund structure and strategy
• Product‑level requirements such as risk retention, concentration limits and leverage caps
• Liquidity management tool selection, disclosures and activation requirements
• Expanded rules on delegation, governance and supervisory reporting
• Developments affecting marketing, management company activities and depositary services
• Key national differences and what they mean for cross‑border operations
• Transitional arrangements and preparation ahead of April 2026