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ARTICLE · 01 SEPTEMBER 2025

Investment Management Client Alert August 2025

K&L Gates
K&L Gates
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On 8 August 2025, the German Federal Ministry of Finance (Bundesministerium der Finanzen) (BMF) published a draft bill for the Fund Risk Limitation Act (Fondsrisikobegrenzungsgesetz) (FoRG).

European UnionFinance and Banking
Philipp Riedl
Philipp Riedl
Hilger Von Livonius
Hilger Von Livonius

BMF Publishes Draft Bill on Fund Risk Limitation Act

On 8 August 2025, the German Federal Ministry of Finance (Bundesministerium der Finanzen) (BMF) published a draft bill for the Fund Risk Limitation Act (Fondsrisikobegrenzungsgesetz) (FoRG). This marks the newly formed government's resumption of the implementation of the Alternative Investment Fund Managers Amending Directive (AIFMD Review). A draft bill on this subject (known as the Fund Market Strengthening Act (Fondsmarktstärkungsgesetz)) had already been published under the previous coalition (Ampelkoalition).

The implementation of the AIFMD Review remains largely unchanged, such as with regard to liquidity management tools (LMTs). The previous legal requirements regarding the redemption period and the suspension of redemptions for open-ended real estate funds are now expressly stipulated as continuing to be mandatory. This then also counts as a selected LMT, meaning that open-ended real estate funds and, if

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