Periodic reporting obligations for non-EEA AIFMs under the Act on the Management of Alternative Investment Funds (AIFMD Annex IV reporting)

Reporting to Finanstilsynet

Non-EEA AIFMs that, under the Norwegian private placement regime, have been granted authorisation by the Norwegian Financial Supervisory Authority (Finanstilsynet) to market units or shares of AIFs to professionals in Norway, are subject to reporting obligations under Article 24 of the AIFMD for the AIFs marketed in Norway. This provision is implemented in the AIF Act section 4-6 and requires an AIFM to report information to Finanstilsynet about the AIFM, as manager, and the AIFs managed and marketed by the AIFM.

Non-EEA AIFMs are not required to report information in respect of AIFs that they manage but which are not marketed in Norway.

AIFMs should start reporting as from the first day of the following quarter after they have information to report until the end of the first reporting period. The information should be provided as soon as possible and not later than one month after the end of the relevant reporting period.

Where the AIF is a fund of funds, this period may be extended by the AIFM by 15 days.

All AIFMs must submit the periodic AIFMD Annex IV reporting through www.Altinn.no.

Reporting through Altinn:

To report through Altinn.no, the AIFM must first register a user. Please see the guidelines. The username must be included in the application form when applying for the authorisation to market AIFs in Norway. Finanstilsynet requires that the username created on Altinn.no must be a generic email address, such as compliance@company.com and match the email address for the account. Individual usernames such as john.doe@company.com will be not be accepted.

Where a third-party reports on behalf of an AIFM, the AIFM must share their user credentials with the third-party.

The AIFM has reporting obligations for all AIFs that the AIFM has been granted authorisation to market in Norway. At each quarter, no later than three weeks before reporting deadline, Finanstilsynet will send reporting forms to the AIFM's Altinn.no account. There will be one form (KRT-1161) per AIFM and one form (KRT-1160) per AIF authorised to market in Norway.

The reporting forms in Altinn.no are partially pre-filled, identifying the AIFM, and where applicable, the AIF. The reporting obligation can be met in one of two ways: Uploading an XML file or by filling out a reporting form.

Quarterly reporting obligation for all AIFMs and AIFs

The 1st of January 2021, Finanstilsynet introduced quarterly reporting for all AIFMs and all AIFs. Should the AIFM's or the AIF's assets indicate a less frequent periodic reporting, according to the AIFMD, the reporting requirement is met by filling a simple reporting form, specifying Total Assets under Management and confirming any use of gearing.

Useful documents:

• Guide: How to create a user in Altinn.no
• Guide: How to log in to Altinn.no
• Guide: How to report AIFMD (Annex IV) in Altinn.no

If your questions are still not answered, please contact us by email:
AIFMD-rapportering@finanstilsynet.no

Reporting XMLs

The XML files must adhere to the ESMA XSDs. These XSD files are adjusted/restricted by Finanstilsynet, such that a single XML file can only contain data regarding one AIF or one AIFM. Please see these adjusted XSD files here:

• No-aifmd_datman_v1.2.xsd (KRT-1161, AIFM-reporting) (xsd)
• No-aifmd_dataif_v1.2.xsd (KRT-1160, AIF-reporting) (xsd)
• No-aifmd_reporting_datatypes_v.1.2.xsd (Both reportings) (xsd)

After the XMLs are uploaded to Altinn.no, the files are validated against the aforementioned XSDs. Here are sample XML files that adhere to these XSD files:

• Example XML file AIF (xml)
• Example XML file AIFM (xml)

FT Identification numbers can be found in Finanstilsynet's registry

For more information about the reporting obligations, AIFMs may refer to ESMA's Guidelines on reporting obligations under Articles 3(3)(d) and 24(1), (2) and (4) of the AIFMD, including Annex I to the guidelines which sets out 'Reporting obligation diagrams' for 'Non-EU AIFMs under Private Placement Regime'. ESMA's final version of the guidelines was published on 8 August 2014 and can be found at:

• Guidelines on reporting obligations under Articles 3(3)(d) and 24(1), (2) and (4) of the AIFMD (pdf)