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 filling reports directly in the Reporter portal using reporting forms 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.

Suomi.fi authentication and authorization (Non-EEA reporters)

In order for the reporter to sign in to the Reporter portal, the portal requires the following from the user:

1. Personal ID to the Suomi.fi system
2. Mandates on behalf of the reporting entity

Carefully read the instructions below on Suomi.fi authentication and authorization. Please also follow the other linked instructions.

Domestic reporters who have Finnish Business ID (Y-tunnus) can find detailed instructions from Reporter portal general Suomi.fi instructions. Please note that unlike for other data collections, mandate specifier ALL is not sufficient. For AIFMD reporting data collection level specifier AIFMD is mandatory.

Detailed instructions on Suomi.fi for non-EEA AIFMD reporters

Detailed instructions for service providers and their client entities

1. Authentication

Assigning mandates to an individual is possible only once the reporter has Suomi.fi user identifier. For Finnish citizens, the ID is their national identification number which allows to log in via f. ex. Personal banking credentials. Foreign citizens are granted IDs via registering to the Finnish Authenticator Identification Service. If mandates are assigned to a foreign individual the mandates are directed to the ID received via Finnish Authenticator Identification Service. For more information about the Finnish Authenticator service, please see the instructions from Suomi.fi’s website.

Please note that the Finnish Authenticator Identification Service is maintained by the DVV (Finnish Digital and Population Data Services Agency). If you encounter issues or have general questions about the service, please contact DVV's Suomi.fi customer service for organizations.

2. Authorization

Users apply for Suomi.fi e-Authorizations mandates on behalf of the reporting entity i.e. AIFM. Mandates are not applied for on behalf of AIFs. When user logs in to the Reporter portal on behalf of the AIFM, the user is also able to submit the AIF reports associated with the AIFM. 

Entities which don’t have Finnish Business ID (Y-tunnus) assign mandates to individuals on behalf of the entity via Authorization with an application. First, fill out a questionnaire which provides you instructions on how to proceed and which documents need to be submitted together with the application. When requirements for the application are established, user can apply on behalf of the entity here. Please note that the processing of the application might take up to 6 weeks.

When mandates are assigned to an individual, the mandate type needs to be either Mandate of transactions or Right to grant a mandate. When mandate is assigned to an entity acting as a service provider the mandate type is Mandate of transactions. Detailed information about different mandate types can be found from FIN-FSA’s description of Suomi.fi e-services and from the glossary of e-Authorisations.

The mandate must include the following attributes:

• Mandate theme: Reporting on financial standing and risks
• Mandate specifier: AIFMD

Please note that if the mandate theme is correct but the mandate is missing the specifier, user’s log in attempt to the Reporter portal is denied. Access to the portal is also denied when the mandate specifier has been written incorrectly.

Examples of assigned mandates.

Please note that the mandate application is submitted to and processed by the DVV (Finnish Digital and Population Data Services Agency). As FIN-FSA and the DVV are different authorities, FIN-FSA helpdesks are unable to provide information on the status of a given mandate application. If you have questions about the status of your mandate application, please contact DVV's Suomi.fi customer service for organizations.

When the application has been filled on behalf of a foreign entity, submit the following information about the assignor from the application to FIN-FSA via email to NewReportingSystem[at]fiva.fi:

• Country code
• VAT number or the business ID issued in the country of registration

Information is filled in the application process during stage ‘Details of the assignor’. Signing in to the Reporter portal on behalf of a Non-EEA entity is denied when FIN-FSA doesn’t have information on the Business ID which the entity uses in Suomi.fi e-services.