Global Regulatory Updates April 2026: AIFMD II implementation, streamlined processes for UCITS in Hong Kong and regulatory fee updates

In this month’s update, our team of lawyers and regulatory experts highlight a range of developments across key jurisdictions.

AIFMD II – Key regulatory changes are now in force

On 16 April 2026, the transposition deadline for European governments to transpose Directive (EU) 2024/927 amending Directives 2011/61/EU and 2009/65/EC as regards delegation arrangements, liquidity risk management, supervisory reporting, the provision of depositary and custody services and loan origination by alternative investment funds (“AIFMD II”) ended, meaning that national European regulators must now comply with the new requirements under AIFMD II.

Further detailed analysis of AIFMD II is available in our Insights tab, where we explore these developments in greater detail.

The key changes concerning the cross-border marketing of investment funds are now reflected on Zeidler Group’s Global Knowledge Hub. Those updates concern Alternative Investment Fund Managers marketing Alternative Investment Funds under Article 36 and Article 42 AIFMD in the European Union, particularly:

• Enhanced disclosure requirements vis-à-vis regulators and investors under the National Private Placement Regimes, including the additional disclosure requirement under Article 23 AIFMD; and
• New conditions for non-EU funds marketing into the EU, including:
  • Prohibition on jurisdictions listed on the EU tax blacklist; and
  • Requirement for an OECD-compliant tax information exchange agreement with the relevant Member State.

Hong Kong – UCITS simplified registration

Our Global Knowledge Hub content has been updated to reflect a new supervisory approach of the Hong Kong Securities and Futures Commission (“SFC”) concerning European UCITS offered in Hong Kong, particularly regarding notification and disclosure requirements.

Prior SFC approval is no longer required for certain material changes, provided that these comply with the regulatory requirements in the UCITS’ Home State. This includes:

• Certain changes to key operators, such as depositaries and investment delegates
• Certain material changes to investment objectives, policies, and restrictions, where these do not involve complex product features or raise local policy concerns.

Belgium – UCITS Regulatory Fees Increase for 2026

The Belgian Regulator, the Financial Services and Markets Authority (“FSMA”), has published its updated fee schedule for 2026.

The revised fees are as follows:

• UCITS notification fee per sub-fund: increased from EUR 505 to EUR 529
• UCITS annual fee per sub-fund: increased from EUR 3,452 to EUR 3,613

Outlook for Global Fund Distribution

For investment managers, staying aware of these changes is essential for ensuring compliance, managing costs, and adapting cross-border distribution strategies.

Zeidler’s Global Knowledge Hub (“GKH”) supports this by providing clear, up-to-date regulatory overviews across more than 80 jurisdictions. Continuously maintained and updated by our team of legal and regulatory specialists, GKH enables firms to efficiently navigate complex global distribution requirements and respond to regulatory changes with confidence.

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