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ARTICLE · 14 APRIL 2025

First Proposals For UK AIFMD II

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HM Treasury (HMT) and the Financial Conduct Authority (FCA) yesterday issued the first in what is expected to be a series of proposals to revise the UK...

United KingdomFinance and Banking
Samuel Brooks
Samuel Brooks
Michael Sholem
Michael Sholem
Bronwyn van Wieringen
Bronwyn van Wieringen

HM Treasury (HMT) and the Financial Conduct Authority (FCA) yesterday issued the first in what is expected to be a series of proposals to revise the UK regime for regulating alternative investment fund managers (AIFMs).

The current regime for UK AIFMs – derived from the EU framework established by AIFM Directive – has remained essentially unchanged since Brexit. The aim of the new proposals is to streamline the regulation of AIFMs, and to adopt a more flexible approach to regulation that is more proportionate to an AIFM's size and activities.

Key proposals

The key proposals, set out in an HMT consultation paper and an FCA call for input, include:

  • abolishing the distinction between "full-scope" and "sub-threshold" AIFMs – in its place, power would be given to the FCA to determine a more tailored approach and to decide which rules should apply to which AIFMs, based on factors such as their size, their investment activities, their investor base and the

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