More detailed instructions on AIFMD reporting

In AIFMD reporting, the data must be reported in the XML format (Extensible Markup Language) in accordance with ESMA's (European Securities and Markets Authority) requirements. The reports are submitted to the FIN-FSA, which forwards them to ESMA. One of the prerequisites for the registration or authorisation of domestic AIFMs and for the marketing permission of foreign AIFMs is the fulfilment of regulatory reporting obligations. AIFMD reports may be generated either using the reporting application provided by the FIN-FSA or produced by the reporting agent itself based on the description of electronic reporting.

Reporting obligation

The AIFMD reporting obligation starts from the beginning of the quarter after the granting of the AIFM authorisation or registration (domestic market participants) or the marketing permission (foreign market participants). The reporting obligation concerning each new fund also starts from the beginning of the quarter after the marketing permission was granted. For example, if marketing permission was granted on 28 November 2018, the reporting obligation begins on 1 January 2019 and the first reporting date is either 31 March 2019 (Q), 30 June 2019 (H) or 31 December 2019 (Y) depending on the reporting frequency applicable to the reportable entity. The start of the reporting obligation does not depend from the launch of activities. If there are no activities, a so-called zero report is sent (No Reporting flag = true)

AIFMD reporting deadlines:

If the deadline is on a weekend or public holiday, it is deferred to the next banking day.

When the activities of a domestic reportable entity cease, it must be notified without delay to the FIN-FSA at AIFM-ilmoitukset(at)fiva.fi.

When the activities of a foreign reportable entity in Finland cease, it must be notified without delay to the FIN-FSA at AIFM-ilmoitukset(at)fiva.fi. The AIFM may cease marketing in Finland, if:

1. a blanket offer is made to repurchase or redeem, free of any charges or deductions, all such AIF units or shares held by investors in Finland, which is publicly available for at least 30 working days, and is addressed, directly or through financial intermediaries, individually to all investors whose identity is known;
2. the third-country AIFM has made a notification of its intention to cease marketing in Finland the units or shares of an EEA AIF or a third-country AIF, which has been published by means of a publicly available medium, which is customary for the marketing of the said AIF and suitable for a typical AIF investor, and
3. any contractual arrangements with financial intermediaries or agents are modified or terminated with effect from the date of cessation of marketing in order to prevent any new or further, direct or indirect, offering or placement in Finland of the units or shares of an EEA AIF or a third-country AIF.

That which is provided for the obligation to make a repurchase or redemption offer shall not apply to closed-ended AIFs.

The third-country AIFM shall submit to the FIN-FSA a notification containing the information referred to in paragraphs 1–3. in addition to this the AIFM must comply with provisions laid down in chapter 20, section 5 a, subsections 4 – 6 of the AIFM act.

The de-notification can be made by using the following template:

• Template for de-notification for Non EEA AIFMs

The notification shall be sent by email to the address AIFM-ilmoitukset(at)fiva.fi.

The FIN-FSA register is not updated based on information reported in AIFMD reporting, but the updating of the register is contingent on the abovementioned notification of the termination of activities.

FIN-FSA registers:

• List of supervised entities (domestic market participants)
• List of notifications (foreign market participants)

The AIFMD reporting obligation ceases at the end of the quarter when the fund was terminated or the marketing of a foreign fund in Finland ends. In this case, one must send a so-called final report (Last reporting flag = TRUE) For example, where activities end on 3 April 2019, the final reporting is submitted as at 30 June 2019.

Reporting application

The FIN-FSA has developed an Excel-based reporting application enabling the generation of encrypted XML reporting files required from the reporting agents. The reporting application is an aid provided for the user, who is solely responsible for its installation and use. The FIN-FSA is not under an obligation to provide a reporting application, and therefore the fulfilment of the reporting obligation may not be dependent on the use of a voluntary tool.

The reporting application is available for downloading in the FIN-FSA's Jakelu distribution service.

The downloadable AIFMD reporting package contains:

• Reporting application (.exe)
• Excel workbook (including information on the manager and funds received on the reporting obligation notification form)
• AIFMD Structure Appendix
• User instructions (fi, sv ,en)
• AIFMD description of electronic reporting (fi, sv, en)

The reporting package (.zip) downloaded from the Jakelu distribution service must first be extracted, after which the application (.exe) must be installed on the reporting agent's personal computer. Subsequently, the report is generated in the final submission file format using the workbook (.xlsx). The submission file is sent as an email attachment to the FIN-FSA.

The identifiers to the Jakelu distribution service are sent to the reporting agent automatically approximately a month before the first reporting date.

The reporting package downloaded from the Jakelu distribution service is specific to the reporting agent (user ID and password). It may only be used to generate reports for the entity concerned. The pre-filled information in the package is based on information from the FIN-FSA's register received in a reporting obligation form sent by the manager. The FIN-FSA recommends that reporting agents always use the newest version of the reporting application, which ensures that the reporting agent has access to an Excel workbook where the pre-filled information is consistent with the FIN-FSA's up-to-date register. If this is not the case, the information in the FIN-FSA's register must be updated using the AIFMD reporting obligation notification form.

After submission, the report sender receives a notification of receipt and subsequently an automatic feedback message indicating the status of the report (Accepted or Rejected) with a Findings attachment (.xlsx) specifying any errors in the report. If the report does not contain errors or its format is not technically approved, there will be no attachment. There may be a delay in the feedback message depending on congestion in the reception system.

Tip: In connection with the “Save report file” function, the reporting application also automatically saves the reporting files in the xml format, which may be used later to help in reporting. The reporting application can also be used to save the csv file. The user instructions of the reporting application contain instructions on how to import data into the workbook. The completed Excel file may also be saved for later use.

Overview of the systems requirements of the reporting application

The workstation must have as its operating system Windows 10 covered by general support as well as Excel 2013 or 2016. The Reporting Application and its workbooks may also work on other versions of Windows and Excel. These are not, however, covered by the support provided by FIN-FSA. More detailed systems requirements are described in the installation and user instructions of the reporting application, which are included in the reporting package downloadable from the Jakelu distribution service.

The FIN-FSA recommends reporting agents to familiarise themselves with the reporting application's user instructions included in the reporting package and the operation of the application well ahead of the reporting deadline. Any technical problems related to the installation or use of the reporting application should be primarily resolved within one's own organisation. However, if a problem cannot be resolved internally, the FIN-FSA requests that you report the problem as precisely as possible (for example, by attaching a screen shot to the description of the incident) by email to AIFMDReportingHelpdesk(at)fiva.fi.