Liquidity management

Liquidity management: new European rules require implementation now

Published by the AFM on 18 March 2026.

In its third AIFMD II update, the AFM explains the new European rules on liquidity
management. The core point is that managers of open-end funds must have at least two
liquidity management tools available, together with a related LMT policy. The AFM also says
these tools must be included in offering documents and fund rules or articles.

The AFM also introduces a procedural change. From 18 March 2026, it applies an adjusted
notification procedure for LMT-related changes and for the activation and deactivation of
liquidity management tools. The message is therefore not only that firms should have the
required tools and policy in place, but also that their notification process should align with the
AFM’s revised approach.

Viela can support managers in structuring this implementation in a practical way. That
includes reviewing whether the selected LMTs are properly reflected in governance and
documentation, helping draft or refine LMT policy, and supporting firms in aligning internal
processes and notifications with the AFM’s updated requirements.