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nid 91759
Apr 08, 2026
tojuri@vixio.com
Netherlands
Dutch Authority for the Financial Markets
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1833 charsNetherlands Financial Authority Issues Guidance on Liquidity Management Instruments Under AIFMD II
On March 17, 2026, the Netherlands Authority for the Financial Markets (AFM) published guidance on liquidity management instruments (LMTs) under the Alternative Investment Fund Managers Directive II (AIFMD II), which comes into effect on April 16, 2026.
AIFMD II introduces new requirements for liquidity risk management. Managers of open-end funds must select and implement at least two relevant LMTs—tools used to manage liquidity risk during market stress. The available LMTs include: suspension of subscriptions, redemptions and repayments; temporary and partial restrictions on redemption requests; extension of notice periods; redemption fees; swing pricing; dual pricing; anti-dilution levies; redemption in kind; and side pockets. Suspension of subscriptions, redemptions and repayments, and side pockets are automatically available to all funds and do not count toward the minimum two-LMT requirement. Managers cannot rely solely on swing pricing or dual pricing to meet the minimum requirement. For money market funds licensed under the Money Market Funds Regulation, only one LMT is required.
Managers must develop detailed policies and procedures governing the selection, activation, deactiveration and calibration of chosen LMTs. These policies must be incorporated into fund documentation and the broader liquidity risk management framework. Existing funds established before April 16, 2026 benefit from a one-year transition period for implementing specific characteristics of selected LMTs, though all other requirements apply from April 16, 2026.
Managers must notify the AFM of selected LMTs, related policies, and any activation or deactivation by April 16, 2026. An updated notification procedure via the AFM portal is available from March 18, 2026. Managers should monitor the AFM website for further updates.
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2019 charsDutch Authority for the Financial Markets Issues AIFMD II Update on Liquidity Management Tools
The Dutch Authority for the Financial Markets (AFM) has published an update on the application of Directive (EU) 2024/927 , the Alternative Investment Fund Managers Directive (AIFMD II) in relation to liquidity management tools.
AIFMD II introduces new requirements for liquidity risk management and the use of liquidity management tools (LMTs). Managers of open-ended funds, including open-ended AIFs and UCITS, must have at least two relevant LMTs and an associated LMT policy. These must be selected from the list in points (2) to (8) of Annex V of Directive 2011/61/EU .
A revised reporting procedure has been established for this purpose, and the AFM update is intended to support managers in preparing for their new obligations in good time. The update states that additional LMTs beyond those provided in the annex are possible but will not count towards the legal minimum requirements. An appropriate LMT policy is also a mandatory component of liquidity management. Managers must have detailed policies and procedures in place for the chosen instruments. These policies and procedures must cover the selection, activation, deactivation, and calibration of the chosen LMTs, as well as the operational and administrative arrangements for their use.
By April 16, 2026, managers must have selected at least two LMTs for the open-ended funds they manage and must have established policies and procedures for activation and deactivation. Investment institutions established before April 16, 2026, may use the one-year transitional period exclusively for the practical implementation of the specifications regarding the features and characteristics of the selected LMTs.
The amended reporting procedure has been available since March 18, 2026, for LMT-related reports, which must be submitted via the AMF Portal. For existing funds that undergo changes in the context of LMTs, notifications can be submitted via the portal using a specific form. This notification must be submitted by 16 April 2026 at the latest.