meta_id 3192744

On May 28, 2026, the Netherlands Official Gazette published Decree 2026-122, implementing European Union Directive 2024/927 into Dutch financial services law. The decree, adopted by the Dutch government on May 4, 2026, amends four regulatory instruments governing investment fund managers: the Prudential Rules Decree, the Conduct Supervision Decree, the Market Access Decree, and the Administrative Penalties Decree for the financial sector. The decree introduces enhanced requirements for alternative investment fund managers (AIFMs) and collective investment undertakings (ICBEs). Key provisions establish mandatory liquidity risk management systems requiring fund managers to monitor liquidity profiles, conduct regular stress tests under both normal and exceptional market conditions, and ensure coherence between investment strategy, liquidity profile, and redemption policies. New rules govern the outsourcing of portfolio management and risk management tasks, requiring managers to notify the Financial Markets Authority (Autoriteit Financiële Markten—AFM) and justify delegation structures with objective arguments. The decree addresses conflicts of interest arising from "white-label" fund arrangements, requiring managers to demonstrate fair treatment of funds and investors when third parties initiate funds or share their names with funds. Additional provisions regulate custodian arrangements for non-European investment funds, permitting Dutch managers to appoint custodians outside the European Union only when equivalent prudential standards apply and information-sharing agreements comply with OECD tax treaty standards. Managers must replace custodians within two years if their jurisdiction becomes designated as high-risk under anti-money laundering standards or is listed as non-cooperative on tax matters. The decree also clarifies requirements for ICBE managers regarding liquidity management instruments and sidepocket provisions. Most provisions enter into force the day after publication in the Official Gazette. Article II, Part F, concerning reporting obligations for alternative investment fund managers, enters into force on April 16, 2027, aligning with corresponding provisions in the Financial Supervision Act (Wet op het financieel toezicht). **Reference:** [Staatsblad 2026, 122](https://zoek.officielebekendmakingen.nl/stb-2026-122.html)