Top 10 things every non-EU AIFM needs to know about AIFMD2

On 16 April 2026, the changes made to the AIFMD by the Amending Directive will start to apply.

The good news for non-EU AIFMs is that these changes do not fundamentally alter either

• the existing national private placement regime (NPPR) framework or

• the reverse enquiry rules.

Nevertheless, minor changes will be made to certain of the disclosures associated with NPPR marketing and some of the procedural requirements are also updated.

To help you prepare for AIFMD2, we have prepared a client note, which sets out the Top 10 Things that we think every non-EU fund manager needs to know and what steps it should be taking to be ready.

The questions we cover in the note are

1. What is AIFMD2 and when does it come into force?

2. How does AIFMD1 apply to non-EU fund managers?

3. How is the pre-contractual disclosure regime changing (Article 23)?

4. How is the annual reporting regime changing (Article 22)?

5. How is the periodic regulatory reporting regime changing (Article 24)?

6. How are the private equity rules changing (Articles 26-30)?

7. Have the national private placement regime (NPPR) conditions been changed?

8. Does AIFMD2 impact the reverse enquiry regime?

9. How does AIFMD2 apply to delegates of EU AIFMs?

10. What should firms do now?

We will be preparing other client notes in due course as we help clients prepare for the introduction of AIFMD2.