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

during the authorisation and registration process
when establishing a new AIF
when an AIFM starts to manage a new AIF in another EEA country
when a non-EEA AIFM starts marketing an AIF under its management in Finland
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.

Matters to be taken into account when submitting the AIFMD report

The FIN-FSA has developed a reporting application that enables the generation of valid XML-format encrypted report files as required from reporting institutions. The application is available for the reporting institutions via the FIN-FSA’s Jakelu Distribution Service. A reporting institution may also create the required reports using methods of its own in accordance with the instructions on electronic AIMFD reporting. Reports are to be submitted by email as attachment.

The national identification code and login ID for the Jakelu Distribution Service will be sent to the entity only shortly before the first report is due.

The first reporting date is based on data on reporting frequency provided in the AIFMD reporting obligation form. A summary of the first AIFMD reporting will be sent by email to the contact person indicated in the AIFMD reporting obligation form.

Description of electronic AIFMD reporting

The FIN-FSA has updated the description of electronic reporting for creating and submitting AIMFD reporting information to the FIN-FSA. The updated description is published together with regulations and guidelines applicable to AIFMs (regulations and guidelines 4/2014). The description highlights the technical requirements and special national requirements that are not included in ESMA’s technical guidance.

Description of electronic AIFMD reporting