AIFMD - Gap analysis

The AIFM Directive is bringing in an overhaul of the alternative investment fund sector which will see many actors in the investment fund industry needing to assess whether they fall within the scope of the AIFMD and if so, what must be done to comply with the obligations laid down by this Directive.

Where an actor is believed to be outside of the scope of the Alternative Investment Fund Managers Directive, it may nevertheless be necessary to consider the reason for electing for the out of scope status. Could this be liable to change and to what extent?

How can Deloitte help?
Our specialists have a full and comprehensive understanding of not only the implications of the Directive on the investment fund sector, but also the future developments in relation to this, thus providing our clients with a forward looking approach.

The AIFMD can seem like a complex minefield of obligations and requirement but with our client’s business interest in mind, we can guide you through these changes in a methodical and clear manner, ensuring that only the necessary changes are made and most importantly that our client understands the rationale behind these changes.

Our gap analysis service looks to highlight those areas in which our clients will need to implement changes. Our core areas of focus are the following:

  • An acid test for the application of the AIFMD which looks at:

- Do you manage the AIFs from the EU?

- Do you distribute in the EU?

- Is your product domiciled in the EU?

  • Review of current systems and processes against the requirements laid down by the AIFMD.
  • Transparency and disclosure requirements which are an essential part of the Alternative Investment Fund Managers Directive due to the increased investor protection and the need for greater supervision
  • Assistance in Due Diligence procedures which are to be implemented in accordance with the AIFMD requirements
  • Remuneration structure which shall now be published and should therefore be elaborated in order to provide a positive image.


Benjamin Lam

Benjamin Lam

Partner | Audit

Benjamin Lam is a senior partner within Deloitte Luxembourg. He has 28 years of experience in the financial services industry. Benjamin co-leads the Deloitte EMEA Real Estate Funds Initiative group. H... More

Nick Tabone

Nick Tabone

Partner | Private Equity Leader

Nick is a partner within the audit department and has over 20 years' experience in this area. He has enjoyed experiences in three other international Deloitte offices. Nick has gained vast experience ... More

Lize Griffiths

Lize Griffiths

Partner | Real Estate Leader Luxembourg

In her role as Real Estate sector leader for Deloitte Luxembourg and DCE, Lize has the primary responsibility for the real estate services across our audit, tax and consulting functions and driving re... More