AIFMD FAQ

AIFMD Reporting Period Type and Inception date

Reporting period type (AIF Question 8)

The Reporting period type [8] determines the reporting period. The Reporting period start date [6] and Reporting period end date [7] are determined based on it, and as such they do not have to be entered in our templates.

The Reporting period type can have the following values:

Reporting Period Type	Description
Q1	1st quarter of the calendar year
Q2	2nd quarter of the calendar year
Q3	3rd quarter of the calendar year
Q4	4th quarter of the calendar year
H1	1st half of the calendar year
H2	2nd half of the calendar year
Y1	the calendar year
X1	1st quarter to 3rd quarter
X2	2nd quarter to 4th quarter

Inception date (AIF Question 22)

The start date of the Reporting Period Type [8] in the Reporting Period Year [9] must be on or after the Inception Date [22].

The table below shows examples for a fund with a yearly reporting obligation.

Example Inception Date	Reporting Period Type	Description
2021-06-06	Y1	Inception date before this reporting year, report the whole year.
2022-01-28	X2	Inception date in Q1, report over Q2, Q3 & Q4.
2022-04-08	H2	Inception date in Q2, report over Q3 & Q4.
2022-08-06	Q4	Inception date in Q3, report over Q4 only.
2022-10-01	Q4	Inception date at start of Q4, report over Q4 only.

Exception for the BaFin (Germany)

The ESMA checks: “The inception date should not be after the start date of the reporting period.”. So the inception date can be equal to the reporting period start date.

The BaFin checks: “The inception date is not allowed as it should be before the reporting start date”. So the inception date can not be equal to the reporting period start date.

Which leads to the difference that e.g. 1 July gets Reporting Period Type H2 according to the ESMA rules and Q4 according to the BaFin rules.

The Matterhorn software automatically handles these subtle differences between reporting countries.

Explanation on Inception date of the AIF by the ESMA AIFMD Q&A:

Question 12 [last update 25 March 2014]:

According to question 22 of the consolidated reporting template, AIFMs must indicate the inception date of the AIF. What does inception date mean?

Answer 12:

If an AIF is subject to pre-authorisation, the inception date should be the date of authorisation. If an AIF is established without pre-authorisation by the competent authority, the inception date should be the date when the AIF was established. Finally, if the AIF is subject to registration obligation at national level with its competent authority after the date of establishment, the inception date should be the date when the AIF was constituted.

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