ESMA to collect data on costs charged by AIFs and UCITS

As part of the package of recent amendments to the AIFMD and the UCITS Directive (generally referred to as 'AIFMD 2.0'), ESMA was mandated to report to the European Commission, Council of the EU (Council) and the European Parliament (EP) by 16 October 2025,

• assessing the costs charged to investors by AIFMs or UCITS ManCos

• explaining the reasons for the level of those costs and for any differences between them, including differences resulting from the nature of the AIFs or UCITS concerned.

To carry out that assessment, the EU NCAs are required to provide ESMA (on a one-time basis) with data on costs including all fees, charges and expenses

• borne directly or indirectly by investors, or by the AIFM or UCITS ManCo  in connection with the operations of the AIF or UCITS, and

• that are to be directly or indirectly allocated to the AIF or UCITS.

ESMA's data collection exercise

ESMA has now announced that, together with the NCAs, it is launching a two-stage data collection exercise, which will involve both manufacturers and distributors of investment funds.

• Information requested from manufacturers will provide an indication on the different costs charged for the management of the investment funds. 

• Information requested from distributors (i.e., investment firms, independent financial advisors, neo-brokers) will inform on the fees paid directly by investors to distributors.

The data collected will form part of the report due to be submitted in October 2025 but will also be part of an enhanced 2025 ESMA market report on costs and performance of EU retail investment products.

Costs and the Retail Investment Strategy

There are, of course, proposals under the EU's Retail Investment Strategy (RIS) to amend the AIFMD and UCITS Directive to prevent undue costs being charged to investors, although the detail of these is still to be finalised through trilogues between the Council and the EP

We will continue to follow developments closely both in relation to the newly announced data collection exercise and the RIS and will be reporting on these when there are developments.