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Requirements applicable to AIFMD managers performing investment services


Published: 06 November 2014


With which requirements must AIFMD managers comply if they also perform investment services?


Brief answer Subject to explicit approval by the AFM, an AIFMD manager may perform the following investment services: (1) managing individual assets, (2) giving advice and (3) receiving and transmitting orders. In addition, the AIFMD manager may perform the ancillary service of custody and administration of units in investment funds and UCITS. The AIFMD manager must however comply with the legal requirements pertaining to these services, i.e. it is subject to the same requirements as investment firms performing these activities. The requirements that apply depend on the nature of the activities that the institution performs rather than on its authorisation.

The following requirements apply to AIFMD managers performing investment services:

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Own funds

At least €125,000

The highest of the CRD IV and AIFMD requirements apply.


Highest of:

1) The AIFMD capital requirement or

2) The CRD IV capital requirement

The highest of the CRD IV and AIFMD requirements apply.

Consolidated supervision

Yes, insofar as relevant, based on CRD IV

Consolidated supervision does not apply to institutions qualifying as a firm under CRD IV.

Consolidated supervision applies to institutions qualifying as an investment firm under CRD IV.


AIFMD reports as well as CRD IV reports

The reporting sets from both directives must be submitted



Performing individual as well as collective asset management may involve risks, which the institution must address in its ICAAP.

DNO required


The obligation to obtain a declaration of no-objection prior to acquiring a holding in an institution does not apply for investment funds (prior approval).

Remuneration policy


The AFM is responsible for supervision on remuneration policies of investment funds. The decision whether to impose CRD IV remuneration policy requirements on these institutions lies with the AFM.

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