AIFMD 2 - Liquidity Management Transformed

The amended AIFMD (AIFMD 2) heralds a new era for liquidity risk management protocols across the European funds industry.

Together with the European Commission’s recently published proposed Level 2 Regulatory Technical Standards (RTS) and ESMA’s Guidelines on liquidity management tools (LMTs), AIFMD 2 reshapes how UCITS (where relevant, in conjunction with UCITS ManCos) and AIFMs of open-ended AIFs select, implement, and govern LMTs.

The changes under AIFMD 2 come into effect on 16 April 2026.

This Simmons client briefing note examines the new requirements and provides practical guidance for managers of both UCITS and open-ended AIFs.

Contents

1. Introduction
2. Background: Regulatory and market drivers for change
3. Impact on UCITS and AIFs
4. Implementation Roadmap for Managers
5. Next Steps
6. Implementation timelines and key dates
Appendix Summary of changes to key documents