AIFMD 2 – ESMA publishes LMT Guidelines

As 16 April 2026 gets closer - the start date for most of the changes made to AIFMD and UCITS Directive by the Amending Directive (AIFMD 2) - more pieces are beginning to fall into place.

On 12 March 2026, ESMA formally published its Guidelines for UCITS and open-ended AIFs on Liquidity Management Tools.

The Guidelines look to establish consistent, efficient and effective supervisory practices and to ensure the common, uniform and consistent application of EU law when a UCITS or open-ended AIF selects, activates and calibrates a Liquidity Management Tool (LMT). The Guidelines note, though, that the primary responsibility for LMTs remains with the UCITS and AIFMs.

The Level 3 Guidelines follow the publication in the OJ, on 27 February 2026, of the Level 2 RTS

• for open-ended AIFs and
• for UCITS.

What happens next?

Both sets of Level 2 RTS apply from 16 April 2026.

The Guidelines apply from the same date, though, funds already in existence before that date are given an extra 12 months, i.e., to 16 April 2027 before they apply.

NCAs have until 12 May 2026 to notify ESMA whether they comply or intend to comply with the guidelines, giving reasons in the case of non-compliance.

Where to find out more

Our client note on LMTs, ‘AIFMD 2 – Liquidity Management Transformed’ can be found here.

Our AIFMD 2 Overview Note on LMTs can be found here.

Our other AIFMD 2.0 Overviews, looking at the key changes made to AIFMD by the Amending Directive, can be found here.