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By Dr. Sebastiaan Niels Hooghiemstra*
On 26 July, the European Commission (the “EC”) published its long-awaited replies to the questions raised by the European Supervisory Authorities’ letter of 7 January 2021 (the “QA”). In its reply, the EC confirmed that Regulation (EU) 2019/2088, as amended (the “SFDR”) applies to all types of alternative investment fund managers (“AIFMs”), irrespective of whether these are authorized, registered (i.e. “small”), EU or non-EU AIFMs. Despite the QA clarification with respect to the applicability of the SFDR to “small AIFMs” and their AIFs, this contribution explains that there remain still several uncertainties for small AIFMs with respect to the practical application of the SFDR entity- and product-level...
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