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AFM update on non-EU funds and fund managers

Reported by Regulationtomorrow
Apr 17, 2026· 2 min read
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Key Takeaways
  • • The AFM update addresses revised regulatory conditions for non-EU alternative investment fund managers (AIFMs) marketing non-EU funds, indicating stricter compliance requirements are now in effect.
  • • This guidance update is part of a broader initiative to transition existing policy from the Adjudicator's Field Manual into a centralized Policy Manual repository.
  • • The fourth edition of the AIFMD II Update: Non-EU establishes enhanced requirements applicable to non-EU AIFMs operating under the Alternative Investment Fund Managers Directive framework.
  • • The update consolidates and formalizes previously dispersed policy guidance into a single authoritative source for regulatory compliance.
Summary
Regulationtomorrow.com has published an AFM (Adjudicator's Field Manual) update focused on the regulatory framework governing non-EU alternative investment fund managers and their ability to market non-EU funds to European investors. The update reflects revised conditions that increase compliance obligations for affected fund managers and administrators.

This update is part of a systematic initiative to migrate existing policy guidance from the fragmented Adjudicator's Field Manual into a consolidated Policy Manual framework. This modernization effort aims to improve regulatory transparency and consistency by centralizing guidance that was previously distributed across multiple policy documents and memoranda.

The substantive focus of the update is the fourth edition of the AIFMD II Update: Non-EU, which outlines enhanced requirements applicable specifically to non-EU alternative investment fund managers. These stricter requirements govern how non-EU AIFMs may market their funds and establish the compliance conditions they must satisfy. The guidance reflects evolving regulatory expectations under the Alternative Investment Fund Managers Directive (AIFMD II) framework, indicating that regulators have heightened scrutiny of cross-border fund management activities.

The consolidation of AFM content into a centralized Policy Manual improves accessibility and reduces compliance friction by providing fund managers and their legal advisors with a single authoritative source for policy requirements, rather than requiring consultation of multiple historical memoranda and policy documents. This update is relevant to institutional investors allocating capital to alternative investment vehicles with non-EU management structures or fund domiciles.

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Sources

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Regulationtomorrow AFM update on non-EU funds and fund managers