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The AIFM Directive is a managers’ directive as opposed to regulating AIFs themselves. The AIFMD seeks to harmonise the regulation of AIFMs. The passport is a means for AIFMs to demonstrate that they have attained the necessary requirements to be allowed to act as an Alternative Investment Fund Manager in the EU to market AIFs from any other EU Member States.

The passport will become available from 2013 at the latest, once the Directive’s transposition date has passed and until 2015 will only be available to EU AIFMs marketing EU AIFs. From 2015, EU AIFMs will be able to use the passport for the marketing of non-EU AIFs and depending on the outcome of the ESMA analysis of the passport’s success, the passport will become available for non-EU AIFMs wishing to market AIFs in the EU.

In the meantime, the national private placement regime may continue to exist for non-EU AIFMs and non-professional investors, requiring a registration in each country of distribution. It is expected that the private placement regime will continue to exist alongside the passport until 2018.

How can Deloitte help?

Our fund registration and distribution team has acquired in depth knowledge of the international distribution of investment funds. The team, through its far reaching established network with various national regulators can offer our clients the following services:

  • Application to the CSSF for the passport and registration of the AIFM and its respective AIFs
  • Analysis of domestic regulatory distribution rules, providing our clients with up to date news and advice to assist them with their marketing procedures
  • Review of marketing materials
  • Private placement advice across the EU whilst this continues to exist alongside the passport.


  • Benjamin Collette
    Partner - EMEA AIFMD Leader
  • Lou Kiesch
    Partner - Regulatory Consulting

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