Those AIFMs that have been authorised under the AIFMD for some time will probably have gotten used to the AIFMD reporting requirements set out in SUP 16.18.
However for those AIFMs that have only recently been authorised a reminder that the reporting period is based upon the calendar year and is not based upon a firm’s accounting year. As such January 2015 will be a busy time as the 31 December 2014 is a reporting period applicable to all AIFMs, with a requirement to provide the information no later than one month after the period end.
Small AIFMs have to report annually to 31 December each calendar year whilst larger AIFMs have to report either half-yearly (to 30 June and 31 December) or quarterly (as half-yearly plus 31 March and 30 September) – see the table in SUP 16.18.4 for further details.
The procedure for first time AIFMD reporting is set out in ESMA Guidelines. AIFMs should start reporting as from the first day of the following quarter day until the end of the first reporting period. By way of example, a small AIFM authorised on 22 July 2014 (i.e. in Q3) would start reporting information as from 1 October 2014 to 31 December 2014; thereafter the firm would revert to annual reporting.
Please see our ‘Alert’ for further details, including the use of new forms AIF001 and AIF002.