By Jasper Koch, Business Development Director, Netherlands
Compliance under the AIFM-light regime is under the spotlight. In a sector-wide letter issued on 30 June 2025, the Dutch Authority for the Financial Market (AFM) made it clear: gaps in compliance won’t be tolerated. This succinct guide cuts through the complexity, breaking down what fund managers in the Netherlands need to know to avoid penalties and stay compliant.
What is AIFM-light?
AIFM-light is the Netherlands’ streamlined regulatory framework for smaller alternative investment fund managers. It comes with lighter requirements, but that doesn’t mean less scrutiny. The AFM expects managers to be just as diligent and proactive as under the full regime.
Where fund managers are falling short
There are several recurring issues, including:
- Outdated or missing Wwft (AML/CFT) risk assessments
- Insufficient client due diligence and lack of source of funds verification
- Incomplete or incorrect AML questionnaires
- Investor misclassification, including wrongly labelling retail investors as professional
- Breaching the 150 retail investor threshold
- Failure to deregister inactive funds or managers
What the AFM expects
The message from the regulator is clear: documentation alone isn’t enough. Managers need to have processes that work in practice and hold up under scrutiny.
Here’s what the AFM is looking for:
- Proactive and operational compliance not just policies on paper
- Immediate review and update of AML, Wwft and onboarding frameworks
- Accurate investor classification – natural persons can’t be classified as professional investors under the light regime
- Control over public offers – publishing detailed fund information online can count as a public offer, pushing you over the 150-person limit
- Under the Packaged Retail and Insurance-based Investment Products (PRIIPs) regulation, any provider of retail investment products – including light managers – must prepare and provide a Key Information Document (KID), also known as the Essentiële-informatiedocument (EID), to potentiawl retail investors before they invest
How can we help
At IQ-EQ, we help fund managers strengthen their compliance frameworks with targeted solutions. These include:
- Custom Wwft risk assessments and AML policy design
- Enhanced KYC and onboarding workflows
- Support with AFM filings, questionnaires and ongoing reporting
- Investor classification tools and registration checks
- Tailored PRIIPs compliance solutions and broader regulatory support for fund managers
- Our proprietary compliance platform, MaxComply, streamlines AML and KYC processes, automates risk monitoring and keeps you audit-ready
If you’re managing funds under the AIFM-light regime and want to reduce your regulatory risk, we’re here to help. Get in touch to discuss how we can support your compliance journey.
