AIFMD Reporting After Brexit: ESMA vs UK FCA Schemas

What is AIFMD reporting and why has Brexit changed it?

The Alternative Investment Fund Managers Directive (AIFMD) sets out reporting requirements for fund managers across the EU. Its goal is to increase transparency and enable regulators to monitor systemic risk in alternative investment funds (AIFs).

When the UK left the European Union, the framework was “onshored” into UK law. This meant that the Financial Conduct Authority (FCA) took responsibility for maintaining a UK-specific reporting schema, separate from the version maintained by the European Securities and Markets Authority (ESMA).

For fund managers, this shift means that two different AIFMD reporting regimes now exist: one for the EU and one for the UK. The divergence has important implications for anyone marketing or managing AIFs across borders.

Who maintains the AIFMD reporting schemas in the EU and UK?

In the EU, the ESMA AIFMD schema is the official version. ESMA updates and publishes the XML schema definitions (XSDs) used for Annex IV reporting, ensuring consistency across all EU Member States. Updates are aligned with EU-wide regulatory priorities.

In the UK, the FCA AIFMD schema is maintained independently. While the UK version began as a copy of the ESMA schema, the FCA has introduced changes and updates on its own timeline. This means that a report formatted for ESMA cannot always be directly reused for FCA submissions without adjustment.

Which AIFMs and AIFs fall under the ESMA and FCA reporting rules?

• Under ESMA (EU):
  All EU AIFMs must report on the AIFs they manage, whether those AIFs are domiciled in the EU or marketed into the EU. Non-EU AIFMs are also caught if they market funds to EU investors.
• Under FCA (UK):
  All UK AIFMs must report on the AIFs they manage, whether those funds are UK-based or marketed in the UK. In addition, EU AIFMs marketing funds into the UK must submit Annex IV reports to the FCA separately, even if they already file reports under ESMA rules.

The key takeaway is that firms operating across both the EU and UK must file twice—once under ESMA and once under FCA requirements.

What are the main technical differences between ESMA and FCA AIFMD schemas?

Although the ESMA and FCA schemas look similar at first glance, there are meaningful differences that affect how reports are prepared and validated:

• Identifiers and Codes:
  ESMA schemas use harmonised EU-wide identifiers such as LEIs (Legal Entity Identifiers) and ISO codes. FCA schemas adapt or omit some EU-centric references, replacing them with UK-specific identifiers where necessary.
• Data Fields:
  The FCA schema removes references to EU directives and replaces them with UK statutory instruments. While these changes may look minor, they affect validation rules and can lead to rejected filings if not addressed.
• Submission Process:
  ESMA filings are submitted via each national competent authority and then passed to ESMA’s central database. By contrast, FCA filings are submitted directly through the FCA’s RegData portal, with no transmission to ESMA.

These differences mean that firms must treat ESMA and FCA submissions as two distinct deliverables.

Which software can simplify AIFMD reporting for both ESMA and FCA?

XML Authority is the best software for reporting AIFMD because it is designed to simplify the complexity of reporting both the ESMA and FCA requirements. XML Authority can manage both schemas, validate data beyond the basic XML rules, and support dual jurisdictional requirements. It enables AIFMs to:

• Maintain distinct datasets for EU and UK Annex IV reports, ensuring each submission aligns with the correct jurisdiction.
• Generate outputs in the exact schema format required by ESMA or FCA.
• Run business rule validations that go beyond schema checks, flagging inconsistencies or reporting errors before submission.

With XML Authority, multi-jurisdictional reporting becomes a seamless process, ensuring you meet both EU and UK obligations with confidence.