Global Fund Distribution Update May 2026

As global fund distribution frameworks continue to evolve, regulators are introducing new disclosure requirements, refining marketing rules, and updating operational and registration frameworks across key jurisdictions. For investment managers operating internationally, staying informed of these developments remains essential for maintaining compliant and efficient cross-border distribution strategies. 

In this month’s update, our team of lawyers and regulatory experts highlight regulatory developments across multiple jurisdictions, including Taiwan, Bulgaria, Germany and Ireland, which are now reflected in Zeidler’s Global Knowledge Hub. Zeidler’s Global Knowledge Hub (“GKH”) provides consolidated regulatory intelligence, practical guidance and continuously updated legal and compliance content across more than 80 jurisdictions worldwide. 

AIFMD II  

The transposition deadline of 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 on 16 April 2026 meaning financial market participants must now comply with the new requirements under AIFMD II. 

Please also refer to the analysis of AIFMD II, which is available in our Insights tab, where we explore these developments in greater detail. 

In general, AIFMD II makes changes to a broad range of topics, including: 

• Delegation and substance requirements  

• Depositary arrangements  

• Loan origination  

• Liquidity management tools (“LMTs”)  

• Reporting and disclosure obligations  

• National Private Placement Regime (“NPPR”) requirements  

• Additional services that AIFMs may provide  

Last month, we reported on the key changes concerning the cross-border marketing of investment funds, such as the enhanced disclosure requirements under the National Private Placement Regimes and the new conditions for non-EU funds marketing into the EU, including the prohibition on jurisdictions listed on the EU tax blacklist and the requirement for an OECD-compliant tax information exchange agreements.  

To provide further guidance to our clients, we have created a Q&A, providing practical guidance on the key amendments introduced under AIFMD II to both the Alternative Investment Fund Managers Directive (“AIFMD”) and the UCITS Directive. In light of the new requirements applicable to third-country AIFMs, the Q&A section in our Global Knowledge Hub also includes an overview table listing the cooperation agreements corresponding to Article 26 of the OECD Model Tax Convention on Income and Capital. 

Taiwan  

Recent regulatory changes introduced by the Financial Services Commission (“FSC”) and the Securities Investment Trust and Consulting Association (“SITCA”) include new ESG disclosure obligations. Under these obligations, local agents for foreign ESG funds registered in Taiwan must publish annual disclosures within two months of year-end, including ESG portfolio compliance levels, benchmark screening differences (where applicable), and stewardship activities such as engagement and voting actions. 

 Additional developments include: 

• Increase in SITCA legal opinion fee: For applications to register a fund in Taiwan, applicants are required to obtain a legal opinion confirming that investor protection laws in the home jurisdiction of the fund and the manager are at least equivalent to those in Taiwan. In the case of Ireland and Luxembourg, SITCA has commissioned a master legal opinion, which applicants may rely upon by paying a fee to SITCA. This fee has increased from NTD 31,000 to NTD 60,000.  

• Greater flexibility regarding subscription limits for certain fund managers: Generally, Taiwanese investors may not account for more than 50% of a fund’s AUM. However, this limit may be increased to 90% where the relevant fund manager is recognised by the FSC as having established a global or regional fund service institution in Taiwan carrying out core asset management functions, such as investment research, product design, risk control, or investment trading.  

• Revisions to the distribution framework applicable to offshore ETFs: Offshore ETFs may no longer be privately placed in Taiwan under safe harbour exemptions.  

• Private placement framework for non-securities funds: Non-securities funds (including private funds and funds investing in asset classes such as gold, real estate, and commodities) may now be privately placed to Taiwanese investors through certain onshore private placement agents. 

Bulgaria – Introduction of notification fees for EU UCITS  

The Bulgarian Financial Supervision Commission (“FSC”) has introduced fees applicable to the notification for EU UCITS marketing into Bulgaria. The fees are published on the FSC’s website. 

The notification fee is now: 

• EUR 250 per fund; or  

• In the case of umbrella UCITS, EUR 250 per sub-fund. 

Germany – Investment Services Exemption Regime 

On 10 February 2026, the German Location Promotion Act (Standortfördergesetz - “StoFöG”) came into effect.  

The aim of the Local Promotion Act is to strengthen Germany’s position as a business and financial centre, to mobilise private investment and to significantly reduce the bureaucratic burden on businesses operating in Germany. It introduced changes to a number of laws in Germany. Some of the changes impact asset managers, financial service providers and banks. Asset managers may benefit from increased flexibility in structuring investment funds. Tax qualification is retained even for investments in commercial partnerships, offering new structuring options. For Financial service providers and banks, administrative burdens are reduced through the abolition of the employee and complaints register, the reporting system for loans of one million or more, and the list of crypto-securities.  

The German investment services content now reflects amendments to the German Securities Trading Act (Wertpapierhandelsgesetz – “WpHG”) introduced by the Local Promotion Act. The revised guidance addresses circumstances in which third-country firms may be exempted from certain conduct and organisational requirements under the German exemption regime.  

Ireland – Consumer Protection Code 2025 

On 24 March 2026, the Irish Consumer Protection Code 2025 (“CPC 2025”) took effect following a 12-month implementation period.  

The new framework applies to regulated firms interacting with Irish consumers, including: 

• UCITS management companies  

• Self-managed funds  

• Distributors  

• Fund service providers offering UCITS in Ireland  

MiFID service providers generally remain outside the scope. 

Most notably, CPC 2025 introduces stricter consumer disclosure obligations, requiring firms to “inform effectively”, with additional requirements applying to advertisements and investor-facing marketing materials. 

The new rules also introduce more prescriptive risk warning requirements. Certain warnings must now be displayed prominently, including: 

• Bold formatting  

• Boxed presentation  

• Font sizes at least equal to the main body text  

The Central Bank of Ireland also provides some additional guidance on its website and in its Guidance on Securing Customers’ Interests. 

For further information regarding the scope and applicability of CPC 2025, please contact the team. 

Outlook 

These developments reflect the continued changes of global fund distribution frameworks, with regulators placing increased focus on investor disclosure, operational transparency, and enhanced oversight of cross-border activities. 

For investment managers, maintaining visibility over these changes remains essential for ensuring compliance, managing operational risk, and adapting international distribution strategies efficiently. 

Already a GKH subscriber?
Log in now to explore detailed jurisdiction-specific guidance. 

New to the Global Knowledge Hub?
Discover how GKH can support your global distribution strategy with a complimentary trial. Get in touch.