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ARTICLE · 18 MARCH 2026

AIFMD II Brings Clarity To Responsibility For Fund Distribution

Dillon Eustace
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In welcome legislative clarification, AIFMD II provides for circumstances under which a UCITS or AIF is marketed by an EU-regulated distributor...

GlobalFinance and Banking
Derbhil O'Riordan
Derbhil O'Riordan
Áine McCarthy
Áine McCarthy
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For further information on any of the issues discussed in this publication please contact the related contact(s) on this page.

What has changed under AIFMD II?

In welcome legislative clarification, AIFMD II provides for circumstances under which a UCITS or AIF is marketed by an EU-regulated distributor which is not acting on behalf of the relevant management company or AIFM, but is being marketed by that EU-regulated distributor acting on its own behalf.

Effective from 16 April 2026, the revised UCITS and AIFMD frameworks now distinguish between (i) distributors which are acting on behalf of the relevant fund management company when marketing a fund which will continue to fall within the scope of the UCITS and AIFMD delegation rules and (ii) those EU firms regulated under the MiFID or the Insurance Distribution Directive (IDD) frameworks which are acting on their own behalf when marketing the relevant fund. From 16 April 2026, the second category of distributors, being those

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