AIFMD transparency rules

Impact on the annual report

AIFMD includes a range of disclosure requirements with impacts for the annual reports of Alternative Investment Funds (AIFs). These requirements are applicable to AIFs marketed and/or managed in the EU.

Our briefing outlines how, when and which information needs to be disclosed.


The Alternative Investment Fund Managers Directive (AIFMD), which was implemented on 22 July 2013, sets out minimum line items and disclosures that must be presented within an AIF’s annual report. 

The AIF annual report generally reflects existing practices, recognising and relying on existing international and local accounting standards as well as the accounting rules laid down in the fund’s instruments of incorporation. 

However, the Directive does include a number of noteworthy changes and additions, particularly in relation to remuneration, leverage, liquidity and the income and expenditure account. 

Alternative Investment Fund managers (AIFMs) also need to consider potential interaction with the investor disclosure requirements, which relate to pre-investment, regular and periodic disclosures. 

Material changes to pre-investment disclosures must be detailed in the annual report while in other cases it may be appropriate to include certain investor disclosures within the annual report as part of the periodic reporting. This briefing provides suggestions in that regard.


AIFMD annual report

Key elements

This briefing paper covers:

  • Applicability of the AIFMD transparency requirements to different types of AIFM/AIF
  • The income and expenditure account
  • Remuneration disclosures
  • Risk management disclosures
  • Liquidity disclosures
  • Leverage disclosures
  • Potential material changes
  • Sub-threshold AIFMs

Deloitte is actively involved in industry level discussions on AIFMD and changes to the annual report and can assist you in analysing the impact. For more information read our briefing on the AIFMD annual report or contact your Deloitte representative. 

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