Since Brexit, the regulatory landscape for Alternative Investment Fund Managers (AIFMs) has diverged, creating distinct reporting obligations under the EU AIFMD regime (supervised by ESMA) and the UK’s AIFMD regime (supervised by the FCA). While both frameworks share a common origin, the technical schemas for reporting have diverged.

1. Supervisory Authority and Schema Maintenance

• ESMA (EU): Maintains and updates the official AIFMD XSD schemas, aligned with pan-EU regulatory priorities.
• FCA (UK): Publishes its own schemas for Annex IV reporting. Although based on the EU template, these are issued and updated independently, requiring UK AIFMs to use the FCA version.

2. Filing Scope and Entity Classification

• ESMA: Applies to EU AIFMs managing EU and non-EU AIFs marketed within the Union.
• FCA: Applies to UK AIFMs managing UK and non-UK AIFs marketed in the UK. EU AIFMs marketing into the UK must file using FCA templates, separately from ESMA filings.

3. Technical Schema Divergence

• Identifiers & Codes: ESMA schemas use EU-wide identifiers; FCA versions adapt or omit some EU-specific references.
• Data Fields: FCA has replaced references to EU directives with UK statutory instruments, and validation rules differ subtly.
• Submission Process: ESMA filings are submitted through national competent authorities into ESMA’s central repository. FCA filings are made directly to the FCA’s RegData portal.

While the ESMA and FCA requirements both originate from Annex IV, in practice they demand separate requirements.

XML Authority is built to handle this complexity. It allows you to:

• Maintain distinct datasets for ESMA and FCA submissions, ensuring each report reflects the correct jurisdictional requirements.
• Generate outputs in the correct schema for each authority directly from those datasets.
• Validate beyond the schema, with built-in business rule checks that highlight inconsistencies and common reporting pitfalls before submission.

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