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ARTICLE · 25 NOVEMBER 2025

Investment Management Client Alert November 2025

K&L Gates
K&L Gates
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On 29 October 2025, the Federal Cabinet adopted the draft of the Fund Risk Limitation Act (Fondsrisikobegrenzungsgesetz). The planned law is intended primarily to implement the amendments concerning the AIFM Directive

GermanyFinance and Banking
Philipp Riedl
Philipp Riedl
Hilger Von Livonius
Hilger Von Livonius

EU Asset Management and Investment Funds Alert

Government Draft of the Fund Risk Limitation Act

On 29 October 2025, the Federal Cabinet adopted the draft of the Fund Risk Limitation Act (Fondsrisikobegrenzungsgesetz). The planned law is intended primarily to implement the amendments concerning the AIFM Directive. We reported on the changes proposed in the consultation draft in our August-Newsletter. Compared to the August draft, the government draft includes several changes.

The proposal to amend the calculation of thresholds for so-called sub-threshold AIFMs has been dropped. Background: small management companies (Kapitalverwaltungsgesellschaften or KVG) that manage assets only up to a certain threshold (sub-threshold) only need to register with the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht or BaFin) and comply with less stringent requirements. The calculation of these thresholds based on market values of assets

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