pc
nid 91921
Apr 15, 2026
tojuri@vixio.com
Netherlands
Dutch Authority for the Financial Markets
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1667 charsNetherlands' Financial Authority Issues Stricter Requirements for Non-EU Fund Managers
On April 14, 2026, the Netherlands' Authority for the Financial Markets (Autoriteit Financiële Markten — AFM) published its fourth update on the implementation of the revised Alternative Investment Fund Managers Directive II (AIFMD II). The update clarifies enhanced requirements for third-country fund managers seeking to offer non-EU funds in the Netherlands.
Under the new requirements, non-EU fund managers and their funds cannot be established in jurisdictions designated by the European Union as high-risk under anti-money laundering regulations or listed on the EU's non-cooperative tax jurisdictions list. Fund managers must demonstrate to the AFM how they will comply with all applicable legal obligations under AIFMD II. The AFM emphasises that the lists of high-risk and non-cooperative jurisdictions are dynamic, and managers bear responsibility for continuous monitoring and compliance. Non-EU managers or funds already established in such jurisdictions are no longer permitted to offer or register funds in the European Union.
The revised AIFMD II entered into force on April 15, 2024. Member states have until April 16, 2026, to implement the directive into national legislation, after which managers must comply with the new rules.
The AFM is requesting affected non-EU managers to provide information demonstrating how they will meet AIFMD II requirements. This information should be submitted by email to non.eu.notifications@afm.nl. The AFM emphasises that managers should take proactive steps to ensure orderly transition and investor protection compliance.
**Reference:**
Autoriteit Financiële Markten (AFM) — AIFMD II Update (April 14, 2026)
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1522 charsDutch Authority for the Financial Markets Issues AIFMD II Update on Stricter Requirements for Non-EU Fund Managers
On April 14, 2026, the Dutch Authority for the Financial Markets (AFM) published its fourth update on the implementation of Directive (EU) 2024/927 , the Alternative Investment Fund Managers Directive (AIFMD II), regarding requirements for non-EU fund managers.
The update clarifies enhanced requirements for third-country fund managers seeking to offer non-EU funds in the Netherlands. Under the new requirements, non-EU fund managers and their funds cannot be established in jurisdictions designated by the European Union as high risk under anti-money laundering regulations or listed on the EU's non-cooperative tax jurisdictions list.
Fund managers must demonstrate to the AFM how they will comply with all applicable legal obligations under AIFMD II. The AFM emphasises that the lists of high-risk and non-cooperative jurisdictions are dynamic, and managers bear responsibility for continuous monitoring and compliance. Non-EU managers or funds already established in such jurisdictions are no longer permitted to offer or register funds in the European Union.
From April 16, 2026, fund managers must comply with the new requirements under the revised AIFMD II. The AFM is requesting affected non-EU managers to provide information demonstrating how they will meet AIFMD II requirements. This information should be submitted by email to non.eu.notifications@afm.nl .
The AFM emphasises that managers should take proactive steps to ensure an orderly transition and compliance with investor protection requirements.