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ARTICLE · 15 DECEMBER 2025

AIFMD II Implementation: The Final Countdown

Jones Day
Jones Day
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Directive (EU) 2024/927 ("AIFMD II") introduces EU-wide rules for alternative investment fund managers ("AIFMs") regarding loan origination, liquidity management tools for open-ended alternative investment funds ("AIFs") and delegation and substance requirements.

United StatesFinance and Banking
Quirine Eenhorst
Quirine Eenhorst
Patrizia Gioiosa
Patrizia Gioiosa
Ate Van IJlzinga Veenstra
Ate Van IJlzinga Veenstra
Aidan Lawes
Aidan Lawes
Iván Martín-Barbón
Iván Martín-Barbón
Florence Moulin
Florence Moulin
Mathias Raabe
Mathias Raabe
Kenneth J Krupsky
Kenneth J Krupsky
Benne Brouwer
Benne Brouwer
+2 more
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Directive (EU) 2024/927 ("AIFMD II") introduces EU-wide rules for alternative investment fund managers ("AIFMs") regarding loan origination, liquidity management tools for open-ended alternative investment funds ("AIFs") and delegation and substance requirements. With less than six months to go until the implementation deadline, this Alert provides an update on AIFMD II's implementation.

Member States are required to transpose AIFMD II into national law by 16 April 2026. Certain Member States, such as Germany, Luxembourg and the Netherlands, have already published drafts of their implementing legislation, whereas others, such as Belgium, France, Italy and Spain, have yet to do so. In addition, formal adoption of delegating legislation containing regulatory technical standards ("RTS") on, inter alia, liquidity management tools and open-ended loan-originating funds is pending.

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