View the ALFI response.

The long version of the Commission’s questionnaire included 102 questions focussing on many different aspects:

1. Functioning of the AIFMD regulatory framework, scope and authorisation requirements
2. Investor protection
3. International relations
4. Financial stability
5. Investing in private companies
6. Sustainability/ESG
7. Miscellaneous

The final response is in line with ALFI’s feedback on the Commission’s inception impact assessment, putting emphasis on the idea of a targeted review on the application and scope of the directive. Moreover, ALFI is of the view that the impact of the AIFMD on AIFs and AIFMs has been largely positive. The association stated that the general concept of a manager directive should not be put into questions, e.g. by introducing product specific rules. There is primarily a need for stability to ensure the development of a brand and the European Union’s competitiveness. For various reasons, a merger of the UCITS and AIFMD framework should not be made.

ALFI will continue to follow the legislative process. An impact assessment may be published by the European Commission in the second quarter of 2021, and a legislative proposal is currently expected for Q4 2021.