Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 14 OCTOBER 2026

AIFMD II: Key Implementation Developments In Luxembourg

Maples Group
Maples Group
Contributor
Maples Group

Maples Group

The Maples Group, through its leading international law firm, Maples and Calder, advises global...

View firm profile
Explore more from Maples Group

Two years on from the entry into force of Directive (EU) 2024/927, commonly referred to as AIFMD II, the 16 April 2026 transposition deadline has passed, and the state of play across the EU is best described as uneven, with compliance posture increasingly dependent on where an AIFM is authorised. However, Luxembourg, which hosts the largest shares of EU AIFs within the Union, transposed the Directive without material gold-plating.

European UnionFinance and Banking
Antonios Nezeritis
Antonios Nezeritis
Owen Rowlands
Owen Rowlands
Maxime Rosaz
Maxime Rosaz
Author LinkedIn connections

Overview

Two years on from the entry into force of Directive (EU) 2024/927, commonly referred to as AIFMD II, the 16 April 2026 transposition deadline has passed, and the state of play across the EU is best described as uneven, with compliance posture increasingly dependent on where an AIFM is authorised. However, Luxembourg, which hosts the largest shares of EU AIFs within the Union, transposed the Directive without material gold-plating.

The transposition deadline has also brought the EU’s liquidity management tool (LMT) framework into focus. ESMA’s Guidelines on LMTs for UCITS and open ended AIFs were formally published on 12 March 2026, following amendments made in December 2025 to align them with the final Regulatory Technical Standards (RTS) adopted by the European Commission on 17 November 2025 (Commission Delegated Regulation (EU) 2026/465).

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

CSSF Imposes Fine For AML And Sanctions Compliance Violations

Luxembourg's CSSF imposed a €56,000 fine on Stonehage Fleming Luxembourg S.A. for multiple compliance failures, including significant delays in processing sanctions screening alerts and implementing changes to screening lists. At the time of inspection, hundreds of alerts had been treated with substantial delays and 42 alerts remained completely unnoticed by the financial services provider.
LuxembourgFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

CRD VI: The EU's Cross-border Banking Rules Are Changing For Non-EU Institutions. Are You Ready?

The EU's third-country branch regime under CRD VI fundamentally changes how non-EU banks can serve European clients, requiring most institutions to establish authorized branches or subsidiaries by January 2027. With national transposition underway and a critical grandfathering deadline already passed, affected institutions must urgently assess their EU activities, evaluate available exemptions, and determine whether their current operating models remain viable under the harmonized framework.
European UnionFinance and Banking
DLA Piper
DLA Piper
Article

The AIFMD II Directive And Financing Transactions

The Luxembourg law of March 3, 2026 transposed the AIFMD II Directive into national law, introducing significant changes to the regulatory framework governing alternative investment funds. This article examines the practical implications for financing transactions involving Luxembourg AIFs, analyzing how the new rules on loan origination, leverage caps, concentration limits, and enhanced disclosure requirements affect both lenders and borrowers in structured finance arrangements.
LuxembourgFinance and Banking
Dechert
Dechert
Article

Luxembourg Private Funds Organised As Companies: How To Make Them Fit For Purpose

Luxembourg's partnership limited by shares (SCA) offers private fund managers a compelling corporate alternative to the special limited partnership structure, particularly for EU family offices and high-net-worth individuals. When combined with the RAIF regime, this vehicle achieves tax neutrality while maintaining the corporate governance framework that certain investors prefer. The SCA-RAIF structure addresses key legal and tax considerations while providing flexibility for secondary strategies, fund-of-f
LuxembourgFinance and Banking
Loyens & Loeff
Loyens & Loeff
Article

Reverse Solicitation: The Exception That Regulators Expect To Remain Exceptional

Reverse solicitation remains one of the most scrutinised concepts in fund distribution, offering a legitimate route for investment when approached entirely on the investor's initiative. Yet the distinction between genuine unsolicited interest and marketing activity carries significant regulatory consequences, requiring AIFMs to navigate narrow fact-specific exceptions rather than treating it as a designed distribution model.
LuxembourgFinance and Banking
Loyens & Loeff
Loyens & Loeff
Article

Luxembourg Introduces Multi-compartment Structures For Unregulated AIF Limited Partnerships

Luxembourg has introduced a landmark legislative reform allowing unregulated alternative investment fund (AIF) limited partnerships to adopt multi-compartment structures. This development enables fund sponsors to consolidate multiple investment strategies, investor classes, and fund-level structures within a single limited partnership, significantly reducing complexity and administrative burden while maintaining creditor protection and investor segregation.
LuxembourgFinance and Banking
Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
Article

New PRC Offshore Trust Tax Rules – Key Implications For Cayman And BVI Offshore Trust Structures

On 24 July 2026, China's Ministry of Finance and State Taxation Administration jointly issued the Announcement on Individual Income Tax Matters Relating to Offshore Trusts (《财政部 税务总局关于离岸信托个人所 得税有关事项的公告》) (Announcement No. 21 of 2026) (the "Notice"), together with a companion Announcement of the State Taxation Administration on Collection and Administration Matters Relating to Individual Income Tax on Offshore Trusts...
GlobalCorporate/Commercial Law
Maples Group
Maples Group