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Ocorian urges fund managers to act now as AIFMD 2.0 deadline looms

Ocorian urges fund managers to act now as AIFMD 2.0 deadline looms

15 April, 2025

Leading global provider of fund administration, capital markets and fiduciary services, Ocorian, is warning fund managers not to delay preparations for the revised EU Alternative Investment Fund Managers Directive (AIFMD 2.0), which entered into force earlier this year and must be transposed into national law by April 2026.

The directive introduces significant changes to the regulatory landscape for private credit and other alternative investment funds operating across the EU. Managers will face tighter rules on loan origination, increased disclosure and delegation requirements, and closer regulatory scrutiny.

Gerry Warwick, Director, Fund Services UK and Channel Islands at Ocorian, commented: "There’s a very human tendency to think of 2026 as a long way off – but in regulatory terms, it’s just around the corner. Many firms will need to review and adapt core aspects of their fund structures, reporting frameworks and lending strategies in view of the deadline. Those who act early will be in the best position to navigate the change and avoid costly last-minute challenges."

Key areas of change include:

  • Loan origination limits: AIFMD 2.0 introduces new rules around leverage and lending to affiliated entities, placing direct private credit strategies under greater scrutiny.

  • Delegation and substance: Firms delegating core functions to non-EU entities will need to demonstrate stronger oversight and substance in the EU.

  • Data and disclosure: New requirements for enhanced transparency, including investor reporting and supervisory data collection, will require operational upgrades across many firms.

Thomas Fahl, Global Head of AIFM Services at Ocorian, added: "Private markets continue to see strong growth, especially in private credit and real assets – even amidst recent market volatility – but with growth comes scrutiny. AIFMD 2.0 reflects the EU’s intent to bring more consistency and risk controls to the sector. Fund managers should be using time now to run readiness assessments, update governance frameworks and engage with third-party service providers where needed."

Abi Reilly, Partner at Bovill Newgate (an Ocorian company), said: “AIFMD 2.0 signals a renewed regulatory focus on ensuring firms are fit for purpose in today’s complex market environment. This isn’t just about ticking compliance boxes – it’s about making sure governance, risk and data processes are robust, scalable and investor-aligned. The most successful firms will be those that integrate these changes proactively into their broader business strategy. Whilst the UK will not be implementing AIFMD 2.0 and is pursuing its own agenda for AIFM regulation in its recent HM Treasury Consultation and FCA Call for Input, UK AIFMs operating across Europe are likely to opt into the AIFMD 2.0 gold standard.

Bovill Newgate supports fund managers in navigating regulatory change, as part of Ocorian’s tailored services across compliance, administration and reporting.

For more detailed insights from Ocorian’s Thomas Fahl and Gerry Warwick into what AIFMD 2.0 means for fund managers, read more in one of the articles below.