AIFMD II Annex IV Reporting: What Changes April 2026

Directive (EU) 2024/927 — AIFMD II — does not only change how funds are managed. It changes what managers must report and when. The Annex IV reporting framework, which has required AIFMs to file periodic data to their national competent authority since 2013, is being fundamentally revised. New data fields, a new XML-only format, expanded scope to cover UCITS managers, and enhanced delegation disclosure requirements all apply from — or shortly after — the 16 April 2026 transposition deadline.

The challenge for compliance and operations teams is that the changes do not all land on the same date. The AIFMD II Directive itself applies from 16 April 2026. But the revised ESMA Annex IV reporting template — which specifies exactly how new data fields must be structured — will not be finalised until H2 2026, with the first reports using the new template format expected in Q1 2027. In the interim, managers must begin capturing new data categories from April 2026 even though the final output format is not yet set.

This guide explains what is changing, who is affected, what the timeline is, and what compliance teams must do now.

For the broader AIFMD II transposition picture — country-by-country status for Luxembourg, Netherlands, Germany, France, and Ireland — see our AIFMD II transposition tracker. For the liquidity management tool requirements that also apply from 16 April 2026, see our LMT guide. For the loan origination framework, see our loan origination requirements guide.

What Is Annex IV Reporting?

Annex IV of the original AIFMD (Directive 2011/61/EU) sets out the data that alternative investment fund managers must report to their home-state NCA on a periodic basis. Reporting frequency depends on AUM:

• Quarterly: AIFMs with AUM exceeding €1 billion (on a leveraged basis) or €500 million (unleveraged, with no redemption rights for five years)
• Semi-annual: AIFMs below the quarterly threshold but above the registration threshold
• Annual: Sub-threshold AIFMs that have opted into full AIFMD authorisation

Annex IV data covers fund-level information (AIF identity, strategy, investor types, geographic distribution of investors, leverage, liquidity profile, risk measures, portfolio composition) and AIFM-level information (total AUM, number of AIFs managed, domicile, delegation arrangements).

NCAs use this data for systemic risk monitoring, leverage oversight, and supervisory engagement. ESMA collects aggregated data across all EU NCAs and publishes annual reports on EU alternative investment fund market trends.

What AIFMD II Changes in Annex IV

1. New Delegation Disclosure Data Points

The most operationally significant change for most AIFMs is the expanded delegation disclosure requirement. Article 24(2) of AIFMD II (as amended) requires AIFMs to include detailed information on delegation and sub-delegation arrangements in each Annex IV report.

The new mandatory delegation data fields include:

Data Point	Description
Delegated functions	List of portfolio management (PM) and risk management (RM) functions delegated to third parties
Delegate identity	Name, domicile, and NCA of each delegate
Geographic distribution	Breakdown of delegated PM/RM by delegate jurisdiction
Percentage of AUM under delegated PM	Proportion of total AUM where portfolio management has been delegated
Percentage of AUM under delegated RM	Proportion of total AUM where risk management has been delegated
FTEs in delegated functions	Number of full-time equivalent staff at the AIFM actually conducting PM and RM oversight (not at the delegate)
Delegation to third countries	Whether any delegation is to an entity outside the EU/EEA; if so, the regulatory equivalence or supervisory cooperation basis

The FTE disclosure is new and significant. An AIFM that delegates substantially all portfolio management to a London or New York-based sub-advisor must now disclose the number of FTE staff it retains in-house to oversee that delegation. This data will be used by NCAs to assess whether AIFMs have genuine substance — a core supervisory concern under AIFMD II's enhanced delegation oversight framework.

AIFMs with very thin oversight functions relative to the scale of delegation will face scrutiny. ESMA and national NCAs (particularly the AFM in the Netherlands and the CSSF in Luxembourg) have signalled that post-AIFMD II supervisory engagement will be informed by Annex IV delegation data.

2. New Loan Origination Fund Data Fields

AIFMs managing loan-originating AIFs (LOFs) must report additional data from April 2026:

• Whether the AIF meets the definition of a loan-originating AIF (i.e., mainly pursues loan origination, or originated loans represent ≥ 50% of NAV)
• Total value of loans originated during the reporting period
• Portfolio breakdown by: sector of borrower, geographic distribution of borrowers, loan maturity profile, interest rate type (fixed/floating), and currency
• Non-performing loans: value and percentage of total loan portfolio
• Risk retention: confirmation of the 5% retained interest on loans sold (Article 15a(3) of AIFMD II), and the method of retention used (first loss, vertical slice, or on-balance-sheet retention)
• Leverage: use of borrowing and guarantees to originate loans (separate from fund-level leverage)

These fields do not exist in the current Annex IV template. AIFMs with private credit, direct lending, or infrastructure debt strategies should ensure their data infrastructure can produce this data from April 2026 onwards.

3. UCITS Management Companies: New Reporting Obligations

AIFMD II amends the UCITS Directive (2009/65/EC) to require UCITS management companies to file periodic data to their home-state NCA in a format equivalent to Annex IV. This is entirely new — UCITS managers were not covered by the original Annex IV framework.

UCITS management companies must report:

• Total AUM under management (by UCITS fund)
• Delegation arrangements, applying the same delegation disclosure fields as AIFMs (see above)
• Investor type distribution
• Domicile of managed UCITS funds

The UCITS Annex IV-equivalent reporting framework is not yet final — ESMA is developing implementing technical standards (ITS) specifying the exact template. The expectation is that these ITS will be finalised alongside the revised AIFM Annex IV template in H2 2026, with first reporting in Q1 2027. However, the obligation itself arises from AIFMD II transposition date — April 16, 2026.

UCITS managers that are not currently part of a group including an AIFM will need to build Annex IV reporting infrastructure from scratch. This is a significant operational undertaking for standalone UCITS houses.

4. ESG Data — SFDR Integration

AIFMs managing funds that fall within the SFDR Article 8 or Article 9 classification must include additional ESG data in their Annex IV reports. The specific fields are aligned with SFDR principal adverse impact (PAI) disclosures and cover:

• ESG strategy and investment approach (qualitative)
• PAI indicators considered at the fund level
• Sustainability-related objectives pursued (for Article 9 funds)
• Reference to the pre-contractual disclosure filed with the NCA

This integration is intended to allow NCAs to cross-reference Annex IV data with SFDR filings and identify potential greenwashing. For asset managers with large Article 8/9 fund ranges, the data burden is material. The SFDR PAI indicators guide covers the mandatory and opt-in PAI indicators in detail.

The XML Mandate: June 30, 2026

The current Annex IV reporting process allows submission in multiple formats depending on the NCA. Many NCAs accept Excel workbooks or their own national portal formats. AIFMD II and the associated ESMA technical standards mandate a single, harmonised XML format for all Annex IV submissions.

The mandatory XML format requirement takes effect from 30 June 2026 — 75 days after the AIFMD II transposition deadline. This timeline has already been confirmed for EEA NCAs (Norway's Finanstilsynet confirmed the June 30 date in 2025) and EU NCAs are expected to follow the same implementation date.

The XML schema is based on ISO 20022 messaging standards and uses structured XBRL-like tagging. This has implications for:

• Reporting platforms and fund administrators: Solutions that generate Annex IV submissions must be updated to produce compliant XML. Major reporting platforms (Matterhorn RS, Confluence, FE fundinfo, Propel) have indicated their timelines for XML-ready output. Managers using bespoke Excel-based processes must transition to XML-capable tools by June 30.
• NCA portals: NCAs must update their submission portals to accept XML. Some NCAs are behind schedule on this — managers should check with their home NCA on portal readiness.
• Testing: Managers should request test XML submissions with their NCA in advance of the go-live date. Submitting an invalid XML file is treated as a non-submission in most jurisdictions.

For managers currently using fund administrators to handle Annex IV submissions, the key action is to confirm in writing with the administrator that their platform will generate XML-compliant output by June 30, 2026.

The Two-Phase Timeline: What to Do Now vs. What to Wait For

The most common compliance question about AIFMD II Annex IV is: "Do I need to submit a revised Annex IV on April 16?" The answer is no — but you need to start capturing new data now.

Phase	Date	What Happens
Phase 1: Directive applies	16 April 2026	AIFMD II obligations are in force. New delegation disclosure, loan origination, and UCITS reporting obligations arise legally.
Phase 2: ESMA template consultation	H2 2026 (expected)	ESMA publishes draft ITS specifying the revised Annex IV template and the UCITS equivalent. Consultation period.
Phase 3: XML mandate	30 June 2026	All Annex IV submissions must use the XML format regardless of NCA.
Phase 4: Final ITS published	H2 2026–early 2027 (expected)	Final Annex IV template ITS enters into force.
Phase 5: First new-format reports	Q1 2027 (expected for quarterly filers)	First Annex IV reports submitted using the revised template with all new AIFMD II data fields.

The practical implication: AIFMs filing Annex IV reports between April 16 and the date the new template ITS enters into force will file using the existing template — but they should be populating the new data fields internally and tracking them, so that when the new template arrives, the data exists.

Quarterly filers whose next report covers the period April–June 2026 (due in July 2026 approximately) will likely still use the current template. Managers should not assume they can defer data collection to when the new template is published — that risks a scramble to backfill data.

Scope: Who Is Affected

Entity Type	Annual Annex IV?	Quarterly?	New AIFMD II Fields?
Authorised AIFM (above quarterly threshold)	Yes	Yes	Yes — from April 2026
Authorised AIFM (below quarterly threshold)	Yes	No	Yes — from April 2026
Sub-threshold AIFM (registered, opted in)	Yes	No	Yes — from April 2026
UCITS management company (not also AIFM)	New obligation	TBD per ITS	Yes — from April 2026
UCITS management company (also an AIFM)	Yes (existing)	Depends on AUM	Yes — merged or parallel reports TBD
Small AIFM (below registration threshold)	No	No	N/A

The most operationally impacted entities are:

1. AIFMs with significant delegation — because of the FTE and AUM delegation fields
2. Loan-originating AIFs — because of entirely new loan portfolio data fields
3. Standalone UCITS management companies — because they have no current reporting infrastructure

Practical Compliance Steps: April to December 2026

By 16 April 2026

• Map existing delegation arrangements: Identify all third-party PM and RM delegates, their jurisdictions, and the percentage of AUM they manage. This is the raw data for the new delegation disclosure fields.
• Count oversight FTEs: Confirm the number of FTE staff at the AIFM who are genuinely engaged in PM/RM oversight — not those nominally allocated to this function but primarily engaged in sales or other activities.
• Classify loan origination exposure: Determine whether any AIFs you manage meet the LOF definition or otherwise originate loans; confirm your data infrastructure can track loan portfolio composition fields.
• Identify UCITS reporting scope: If you are a pure UCITS manager or manage UCITS alongside AIFs, begin preparing for the UCITS Annex IV equivalent obligation.
• Contact your fund administrator: Confirm their timeline for XML-capable Annex IV output and for integrating the new AIFMD II data fields into their reporting platform.

By 30 June 2026 (XML deadline)

• Test XML submissions: Submit a test XML file to your home NCA before the mandatory date. Identify and resolve any formatting errors.
• Update operational workflows: Transition from Excel or NCA-portal-specific formats to XML as the primary submission method.
• Confirm third-party tool readiness: If using a reporting platform or fund administrator, obtain written confirmation that XML output is live and tested.

H2 2026 (ESMA template consultation)

• Monitor ESMA consultation: When ESMA publishes the draft Annex IV ITS, review it against your data collection systems to identify gaps.
• Respond to ESMA consultation: If data requirements create operational challenges (e.g., FTE categorisation, delegation percentage calculations), submit comments during the consultation period.

Q1 2027 (first new-format reports)

• File under the revised template: Ensure all new data fields are populated. Quarterly filers will be first; semi-annual and annual filers follow.
• Cross-check with SFDR disclosures: Confirm that ESG data in Annex IV is consistent with PAI statements and pre-contractual SFDR disclosures filed for the same period.

Key Questions for Fund Administrators

If you rely on a fund administrator or reporting specialist for Annex IV submissions, these are the questions to ask now:

1. XML readiness: "On what date will your platform produce XML-compliant Annex IV submissions, and have you tested with any EU NCA's portal?"
2. AIFMD II fields: "Which new AIFMD II data fields (delegation FTEs, loan portfolio composition, UCITS equivalents) does your platform currently capture or plan to capture, and by when?"
3. UCITS scope: "Does your service extend to the new UCITS Annex IV equivalent reporting, and what is your timeline for supporting this?"
4. Template updates: "How do you plan to incorporate the revised ESMA Annex IV template ITS when it is finalised, and what notice will you give before live submission changes?"
5. NCA-specific requirements: "Are you tracking any NCA-specific portal requirements (format, submission window, guidance notes) for my home state?"

FAQ

Does AIFMD II change the reporting frequency thresholds?

The frequency thresholds themselves (€1 billion for quarterly, registration threshold for annual) are not changed by AIFMD II. However, the calculation of AUM for threshold purposes now explicitly includes assets managed via delegation — meaning AIFMs that previously excluded delegated AUM from their threshold calculation may find themselves crossing the quarterly threshold.

What happens if my NCA has not updated its portal to accept XML by June 30, 2026?

This is a real risk. Several NCAs are behind schedule on portal updates. ESMA and the ESAs are monitoring NCA readiness. In practice, NCAs that cannot accept XML by June 30 will likely issue transitional guidance permitting continued Excel or CSV submission for a limited period. Managers should not plan on this — but should monitor their home NCA's communications and be prepared for a short delay if it occurs.

Are sub-threshold registered AIFMs (Article 3(3)) affected by the new fields?

Sub-threshold registered AIFMs that have opted into full AIFMD authorisation are subject to Annex IV and will be subject to the new fields. Pure sub-threshold registered AIFMs (who report only basic data under Article 3(3)(d)) are not subject to full Annex IV and the new AIFMD II Annex IV fields do not apply to them directly. However, Member States may choose to extend the new data requirements to sub-threshold managers as part of national transposition — check your home-state implementation.

Does the AIFMD II Annex IV apply to non-EU AIFMs managing EU AIFs?

Non-EU AIFMs that market EU AIFs to EU investors under national private placement regimes (NPPR) file Annex IV with the reference member state NCA. AIFMD II's Annex IV changes apply to these managers in the same way as EU AIFMs — they must report the new delegation, loan origination, and (if applicable) UCITS data fields from April 2026.

Can I query the specific AIFMD II Annex IV requirements for my fund structure?

Yes — use the platform's AI query tool to ask specific questions about your fund type, delegation arrangement, or loan origination strategy. The Argus knowledge base includes the consolidated AIFMD II text, the Commission Delegated Regulation on LMTs, and ESMA supervisory guidance.