AIFMD – Challenges for the Swiss fund industry 

The EU Directive on Alternative Investment Fund Managers (AIFMD) must be implemented by EU member states by the middle of 2013. For the Swiss financial centre, this will require action in order to remain attractive as a centre for investment managers.

What is at issue?


As a reaction to the financial markets crisis, the European Union adopted the AIFM Directive on 11 November 2010 following a lengthy debate. 21 July 2011 marked the Directive’s entry onto force with the beginning of a two-year implementation deadline. The aim of the AIFM Directive is to bring into harmony regulation across the EU concerning the regulatory supervision of managers of alternative investment funds, the provision of services in the EU internal market and the distribution of alternative investment funds.


The AIFMD contains, on the one hand, a licensing and supervisory requirement for all EU-domiciled managers who do not fall directly under the Directive on UCITS. On the other hand, the AIFMD regulates direct access to the EU market for fund managers from third countries and requires equivalent supervision for the delegation of asset management in third countries as well as cooperation between the responsible supervisory authorities.


In order to counter potential isolation of the Swiss fund industry, the Swiss Federal Council opened a consultation process at the beginning of May 2011 in order to amend the Federal Act on the Collective Investment Schemes. The changes to the law includes a broadening of supervision on all asset mangers of Swiss and foreign collective schemes, increases requirements on custodians as well as strengthens provisions regarding distribution.


What are the challenges?


  • What are the effects of the AIFMD on products strategies and business models?
  • What necessary precautions must be taken during the implementation period?
  • How will the state of affairs concerning the Swiss legislation continue to develop?

How can KPMG assist you?


KPMG can help you in proactively addressing the AIFMD topic. We closely monitor ongoing developments and perform a basis valuation of potential effects on your organisation.


  • We support you in improving operations and compliance processes.
  • We help you during the impact analysis of AIFMD and can assist you in the corresponding process steps in your company.

    Markus Schunk

    Markus Schunk

    Partner, Head of Investment Management, Audit Financial Services

    +41 58 249 36 82

    Jürg Leu

    Jürg Leu

    Senior Manager, Attorney-at-Law

    +41 58 249 57 50

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