On 4 December 2019, ESMA added a new question in its Q&A on AIFMD. The question relates to the
reporting obligation for AIFMs, and to the reporting of the results
of liquidity stress tests for closed-ended unleveraged AIFs in
particular. In its answer, ESMA refers to the exemption provided
for those funds in Article 16 (1) of the AIFM Directive and
recommends that AIFMs which manage closed-ended unleveraged AIFs
(i) indicate in the AIFM consolidated reporting template published
by ESMA that the question is not applicable, and (ii) report in
this field the fact that the relevant fund is a closed-ended
unleveraged AIF.
However, in the event where an AIFM does decide to conduct
liquidity stress tests for the unleveraged closed-ended AIFs that
it manages, ESMA states that it should report the results of the
liquidity stress tests in the same field.