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ARTICLE · 03 FEBRUARY 2026

Investment Management Client Alert January 2026

K&L Gates
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On 18 December 2025, the European Securities and Markets Authority (ESMA) published a report on the revised guidelines on liquidity management tools (LMTs) for UCITS and open-ended AIFs

GermanyStrategy
Philipp Riedl
Philipp Riedl
Hilger Von Livonius
Hilger Von Livonius

ESMA Publishes Report on LMT Guidelines

On 18 December 2025, the European Securities and Markets Authority (ESMA) published a report on the revised guidelines on liquidity management tools (LMTs) for UCITS and open-ended AIFs. The amendments are intended to bring the guidelines in line with the regulatory technical standards (RTS) adopted by the EU Commission on 17 November 2025.

Changes have also been made to the provisions for redemption gates. Fund managers of open-ended AIFs (without retail investors and with a limited number of professional investors) should consider using investor-level redemption gates (alone or in combination with fund-level gates) in order to reduce the risk of certain investors gaining an advantage by exiting the fund early.

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