EU AIFMs across the EU will be able to use the transitional relief period of one year provided by their home member state regulators, only two countries intend to limit the transitional period to existing AIFMs (The Netherlands and Latvia). Ireland and Malta even provide a two year period for non-EEA AIFMs.
Until transposition actually takes place in a particular EU member state, non-EU AIFMs should be able to market their non-EU alternative investment funds to investors in that member state by use of the existing private placement regime. After the date of transposition, a non- EU AIFM will need to comply with a number of conditions (including new reporting and disclosure requirements) in order to continue to take advantage of the private placement regime in a given EU member state.
KPMG International has produced an overview of the impacts on AIFMs in the EU. Please view the report (PDF 416 KB).