Today, the directive amending the AIFM Directive and the UCITS Directive has been published in the Official Journal of the European Union.

As a consequence, it will enter into force on the 20th day following such publication, which should be the 15th of April 2024.

That does not mean, however, that it will apply on such date, as it will first need to be transposed into national law. In Luxembourg, that would mean at least amending the law dated 12 July 2013 on AIFMs, and the law dated 17 December 2010 on undertakings for collective investment. A period of 24 months is provided for such transposition into national law.

In addition, a number of so-called “level 2” rules will be prepared by ESMA, such as guidelines relating to liquidity management tools or regulatory and technical standards for open-ended loan originating AIFs. Most of these should be prepared in the next 12 months and therefore be available before the new rules become applicable.