UCITS & AIFMD: the revised Directives take effect on April 16, 2026
Among the changes introduced by these revised UCITS (UCITS) and AIFM (AIFM) directives, all open-ended funds must, as of April 16, 2026, have at least two liquidity management tools.
Selected from the list defined by the AIFMD2 and UCITS regulations, namely:
Redemption caps (gates)
Adjustment of the net asset value (swing pricing)
Adjustable entry/exit fees payable to the fund (anti-dilution levies)
Extension of notice periods
Redemption fees payable to the UCITS (redemption fees)
Redemption in kind
Dual pricing regime (dual pricing) not available in the French market
The segregation of assets (side pockets) and the suspension of subscriptions and redemptions remain under general law and are therefore not included in the list of liquidity management tools that management companies must select under these directives.
Money market funds are required to select only one liquidity management tool.
By April 16, 2026, management companies must finalize with asset servicers the implementation of the selected tools, their operationalization, as well as their terms and timelines.
Open-ended funds established prior to April 16, 2026, have until April 16, 2027, to comply with ESMA’s guidelines and delegated regulations.
Learn more: AIFMD 2: an evolution more than a revolution - Societe Generale Securities Services