meta_id 3091270

On March 19, 2026, the Netherlands enacted legislation implementing European Union Directive 2024/927, which amends Directives 2011/61/EU (Alternative Investment Fund Managers Directive) and 2009/65/EG (Undertakings for Collective Investment in Transferable Securities Directive). The law, formally titled the Implementatiewet gewijzigde AIFM-richtlijn en icbe-richtlijn, introduces comprehensive amendments to the Dutch Financial Supervision Act (Wet op het financieel toezicht). The legislation establishes new regulatory requirements for investment fund managers and collective investment undertakings across several key areas. It introduces definitions and rules for loan-initiating investment funds and loan-initiating fund managers, establishing specific governance and risk management requirements for managers engaging in loan origination activities. The law implements enhanced liquidity risk management provisions, requiring managers to select multiple liquidity management instruments aligned with fund investment strategies and redemption policies. The amendments strengthen anti-money laundering and counter-terrorism financing controls by incorporating references to the Fourth Anti-Money Laundering Directive (2015/849/EU) and OECD Model Tax Convention standards. These provisions require managers and investment funds to be established in jurisdictions not identified as high-risk and that have information-exchange agreements with the Netherlands. The legislation grants the Authority for Financial Markets (Autoriteit Financiële Markten) and the Dutch Central Bank (Nederlandsche Bank) expanded supervisory powers, including authority to request additional data for financial stability purposes and to impose suspension of fund subscriptions, redemptions, and purchases when necessary to protect investors or financial stability. The law entered into force on a date to be determined by royal decree, with provisions allowing different effective dates for specific articles.