AIFMD – Challenges for the Swiss fund industry 

The introduction of the Alternative Investment Fund Managers Directive (AIFMD) in the European Economic Area (EEA) will also affect Swiss financial intermediaries. With the partial revision of the Collective Investment Scheme Act (CISA), important aspects of AIFMD have found their way into Swiss law; however, this does not guarantee automatic access to the EEA. Until further notice, this is why the revised collective investment schemes legislation in Switzerland as well as the AIFMD and the local law of the individual member states will still have to be taken into consideration.

What is it all about?

The AIFMD harmonizes the requirements regarding the management and administration of alternative investment funds (AIF) which are distributed to professional investors in the EU. A central aspect is the regulation of the Alternative Investment Fund Manager (AIFM).


On the one hand, the AIFMD addresses the obligation to hold a license and to be supervised, applicable to all EU-domiciled investment fund managers who are not already subject to the UCITS. On the other hand, it regulates access to the EU market for fund managers coming from non-EU member states, such as Switzerland, and defines the conditions under which asset management may be delegated.


In a first step, the internal market is restricted to EU-based AIFMs and AIFs. Until 2015, Swiss asset managers of collective investment schemes will only have access by observing the relevant national laws on private placement. Under certain circumstances, Swiss asset managers may also benefit from the new passport regime from 2015 onwards. In 2018, the EU Commission will then replace these national laws with the EU passport regime.


However, even in the case of a private placement according to the relevant national laws of a specific EU member state, certain AIFMD rules must still be observed, such as the rules on transparency, the specific rules on the preparation of annual financial reports (especially in regard to the disclosure of remunerations) and the duty to inform investors and regulators.

Strategic questions regarding the AIFMD

  • How will the AIFMD affect product strategies and business models?
  • Under which circumstances can an EU-domiciled collective investment scheme be managed by a Swiss asset manager?
  • How can Swiss asset managers be active under the national laws on private placement?
  • Should Swiss asset managers incorporate a branch office in the EU?

How can KPMG support you?

KPMG helps your company address AIFMD issues in a proactive way. We are constantly observing the latest developments and can therefore provide an in-depth assessment of potential impacts these new rules will have on your organization.


  • We can support you in improving your operational and compliance processes.
  • We can help analyze the impact of AIFMD on your company so you can take the next steps, which we can set up for you.
  • Our international network is at your disposal if you should for example wish to incorporate a branch office in the EU.

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

Investment Management

RollUp Image
Our services for the investment management sector

Regulatory Competence Center

Teaser Image
Our team of qualified financial professionals offers you a wide range of services as well as support with the application and interpretation of regulatory requirements.