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EU asset management regulatory roundup: LMTs under AIFMD/UCITS, Retail Investment Strategy, ESG/Taxonomy, CSRD/CSDDD, EMIR III and AML (January 2026)

Published on: 14 April 2026

Published by a LexisNexis Ireland - Banking & Financial Services expert

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Asset Management & Investment Funds: EU & International Developments—January 2026

Revised guidelines on LMTs under AIFMD and UCITS Directive

ESMA has issued a report setting out an updated iteration of its guidelines on liquidity management tools (LMTs) for UCITS and open-ended AIFs. The guidelines explain how managers should choose and calibrate LMTs having regard to the fund’s investment approach, liquidity characteristics and redemption arrangements. They give effect to mandates in Article 18(a)(4) of the UCITS Directive and Article 16(2)(h) of the AIFMD, each as amended by AIFMD II. ESMA released a final report on the guidelines in April 2025, alongside a final report containing regulatory technical standards (RTS) on LMTs. In November 2025, the European Commission adopted delegated regulations for these RTS (AIFMD RTS and UCITS RTS), which introduced modifications to ESMA’s proposed texts. To align the guidance with the RTS adopted by the Commission, ESMA has introduced targeted updates, addressing in particular redemption gates and the treatment of transaction costs within anti-dilution LMTs. The guidelines will start to apply on the RTS application date, which is specified as 16 April 2026, as specified therein, for the purposes of these guidelines...

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