Eurozone Investment Funds – New Reporting Obligations

New requirements concerning reporting by EU AIFs and UCITS of statistics on their assets have been introduced by the European Central Bank (ECB). The new reporting requirements will apply from 1 December 2025.

The new requirements reflect the concerns of the ECB that, in light of the significant growth in importance of the investment fund subsector for the transmission of monetary policy and financial stability surveillance and assessment, more detailed statistical information is required to be reported to national central banks and the ECB.

Accordingly, the ECB intends to collect more granular data on instruments, including stocks, flows and security-by-security information, using the existing information reported to EU authorities, for example, as a result of AIFMD Annex IV reporting, to the extent possible. The ECB envisages obtaining the information monthly (to the extent practicable) through national central banks. However, there are several grounds for national central banks to permit less frequent reporting, thereby providing some flexibility.

For example, non-UCITS funds will be able to report their statistical information as frequently as they value their assets under their respective national accounting rules, but must do so at least on an annual basis.

Where derogations are granted, the relevant statistical information must be provided by the relevant home member state national central bank to the ECB by close of business on the 28th working day following the end of the period to which the statistical information relates.

The new reporting requirements apply to funds established within the Eurozone. In some cases, the new rules also apply to intermediaries that are required to report statistical information on assets, liabilities, income received, dividends paid and fees paid by the investors to the investment fund.

The new rules do not contemplate application to funds outside the Eurozone exercising the AIFMD marketing passport or registered for marketing under the National Private Placement Regime.

Substantive Requirements

Investment funds are required to report statistical information to their home member state national central bank, in accordance with the requirements set out in Annex I and the descriptions set out in Annex II of the new Regulations.

In summary, this includes, among other things:

• End-of-month stock data on the assets and liabilities of investment funds.¹ This includes deposits and loan claims, debt securities, equity securities (both listed and unlisted), derivatives and non-financial assets, with all data further broken down by geographical focus and time securities are held for.
• Monthly flow data on either the revaluation adjustments or transactions of investment funds, or both.² This includes the same categories of securities discussed above, and with the methodology covering revaluations due to price and exchange rate changes.
• Monthly income received and dividends paid for each share class issued by the investment fund and annual fees paid by the shareholders to the investment fund.³
• Information on the classification of the investment fund.⁴ This includes investment policy, investment style, geographical focus and investor base.

For the purposes of the first two points above, the investment fund must report security-by-security information for debt securities, equity securities and investment fund shares/units, including International Securities Identification Number (ISIN) code, issuer code and issuer location.

Investment funds also have to report statistical information on the residency and institutional sector breakdown of the holders of investment fund registered shares/units issued by investment funds.⁵

Where the residency or institutional sector breakdown of the holder of investment fund registered shares/units issued by investment funds cannot be directly identified, investment funds will need to report the relevant statistical information on the basis of available information.

^{Reference to Regulation (EU) 2024/1988:}

^{1 Specified in Table 1 of Annex I.}

^{2 Specified in Table 2 of Annex I, in accordance with the methodology set out in Annex III.}

^{3 Specified in Table 4 of Annex I.}

^{4 Specified in Table 5 of Annex I.}

^{5 As set out in Tables 1 and 2, section 9 (investment fund shares/units), of Annex I.}