AFM Publishes Letter With Points For Attention To Sub-threshold Managers Under AIFMD

On 30 June 2025, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, AFM) published a letter addressed to sub-threshold managers pursuant to AIFMD (the Letter). The Letter follows a thematic review conducted by the AFM into this segment of the market and outlines key findings, regulatory expectations, and areas of concern. Sub-threshold managers are reminded of their ongoing obligations under the AIFMD registration regime pursuant to Article 2:66a of Dutch Act on Financial Supervision (Wet op het financieel toezicht, AFS) and are urged to assess their compliance accordingly.

Key findings and regulatory expectations

The AFM's review revealed that compliance with ongoing regulatory obligations by sub-threshold managers is inadequate in various areas. The Letter addresses the following areas: