AIFMD reporting

AIMFD reporting means reporting as referred to in the AIFM Directive (2011/61/EU) and the European Commission Regulation (2013/231). The reporting obligations under the AIFM Directive have been implemented in national legislation (Act on alternative investment fund managers (162/2014) and Ministry of Finance Decree on alternative investment fund managers (226/2014)). Chapter 6 of the FIN-FSA’s regulations and guidelines 4/2014 on alternative investment fund managers includes regulations and guidelines on AIFMD reporting.

The regulatory framework requires that alternative investment fund managers (AIFMs) regularly provide information for supervisory purposes both on themselves and on the alternative investment funds (AIFs) they manage. The purpose of AIFMD reporting is to effectively monitor and prevent systemic risk and market disruptions.

The reporting obligation applies to registered and authorised AIFMs, and to those AIFMs that are established in a third country (non-EEA country), which market in Finland the AIFs they manage.

AIFMD reporting comprises the following areas:

  • basic information on the AIFM and the AIFs it manages
  • principal exposures and most important risk concentrations of the AIF
  • risk profile of the AIF
  • leverage of the AIF.

The AIFMD reporting obligation takes effect at the beginning of the next quarter following the approval of the notification on the commencement of marketing. If an AIF receives a marketing authorisation from the FIN-FSA at a time when the AIF is not yet filed in the Finnish Trade Register, the FIN-FSA must be re-notified as soon as the fund is filed and also when fund operations are initiated.

AIFMD reporting obligation notification form

The information to be reported and its timing and frequency depend on the characteristics and assets of the AIFs managed by an AIFM. Information regarding such characteristics and assets is to be reported to the FIN-FSA. The information should be provided

  1. during the authorisation and registration process
  2. when establishing a new AIF
  3. when an AIFM starts to manage a new AIF in another EEA country
  4. when a non-EEA AIFM starts marketing an AIF under its management in Finland
  5. when earlier information reported relevant to AIFMD reporting obligations changes.

All changes relevant to reporting, including new contact persons, are to be notified to FIN-FSA with the form below prior to the change taking effect. The information in the FIN-FSA’s register is collected from reporting obligation notification forms. In AIFMD reporting, if the details identifying the fund manager and the fund do not match the information stored in the FIN-FSA register, the reception of the report fails.

Information relevant to the reporting obligation should be notified with the reporting obligation notification form.

Submitting reports to FIN-FSA

AIFMD reports are submitted through the Reporter portal. Test environment for the portal is the Validation service which must be used for testing validations and report submissions. In the Reporter portal users can create AIFMD reports via reporting forms. Reports created via reporter’s own system needs to follow FIN-FSA’s ESMA description of electronic reporting and be submitted to the Reporter portal.

AIFMD reports are submitted to the Reporter portal from reference date 30 September 2023 onwards. Reports (incl. amendment reports) for the reference date 30 June 2023 and older are submitted via email to the legacy reporting system.

In the Reporter portal users can see reference dates and deadlines for the expected reports, national reporting codes, ESMA reporting codes and funds primary types. The Portal always shows users expected reports for the next quarter meaning, that annual and semi-annual reporters can see their expected reports approximately three months before the reporting reference date. The same information is available also in the Validation service. Communication between the reporter and FIN-FSA are carried out in the Reporter portal via the Discussions feature, excluding reporting obligations notifications forms and de-registrations.

Logging in to the portal requires Suomi.fi personal authentication as well as authorization on behalf of the reporting entity. More information about the required mandates for reporting AIFMD can be found More detailed instructions on AIFMD reporting page. General instructions on Suomi.fi authentication and authorization can be found here.

ESMA reporting guidelines

See also ESMA's Questions and answers on the application of the AIFM Directive (Updated 4 October 2018). ESMA updates the document frequently.

Releases

More detailed instructions on AIFMD reporting

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