The future of AIFMs is multi-jurisdictional and unified
18 Feb 2026
With alternative investment fund managers needing to face up to an increasingly complex investor landscape, the heads of JTC’s Global AIFM Solutions proposition in the UK, Guernsey, Ireland and Luxembourg — Simon Monson, Kobus Cronje, Orla Philippon, and Louis Lamotte — explore how the AIFM market is evolving and why AIFM solutions are proving increasingly attractive
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What are the benefits of EU and non-EU AIFM solutions?
Simon Monson: Ultimately, the benefit of an Alternative Investment Fund Manager (AIFM) solution is to provide global fund managers with a cost-effective service that enables them to operate in compliance with regulatory requirements, by providing appropriate structures and good oversight.
From a UK perspective we are seeing a number of trends in this regard.
In particular, we are seeing a lot of activity in the ‘appointed representative’ programme in the UK whereby we take responsibility for regulating the UK manager entity.
It is a powerful proposition.
Orla Philippon: From an Ireland and wider EU viewpoint, the most obvious benefit an AIFM solution brings to managers is the marketing passport, enabling managers to seamlessly access EU investor capital.
That seamless and blanket access to investors across the EU is one of the key benefits.
Louis Lamotte: There is also an investor aspect.
Being able to provide high levels of investor protection through the strong governance credentials an AIFM solution can bring in stable jurisdictions, offers a great deal of reassurance to managers and of course their underlying investors.
Kobus Cronje:In Guernsey, the biggest advantage is that we are able to offer managers a cost-effective solution looking to market their funds either outside of the EU — including the UK — or to a small number of specific EU Member States.
The Guernsey AIFM solution offers a quicker route to market for non-EU fund promoters and carries a range of cost and flexibility advantages, without compromising on investor protection and the marketability of the funds outside of the EU and to targeted individual EU Member States.
How do you keep pre-marketing compliant but effective?
Lamotte: The differing interpretations of the term ‘marketing’ across Member States has been a consistent challenge since AIFMD was introduced – with new ‘harmonised’ pre-marketing regime brought into the AIFMD by the Cross-Border Distribution Framework (CBDF).
But it is still the case that pre-marketing is an activity that is more regulated than marketing itself.
You can delegate marketing of a fund to someone else, such as a general partner (GP), as long as you can demonstrate you have done proper due diligence.
But when it comes to pre-marketing, the delegation is more restricted — sometimes impossible — leading the AIFM to conduct the marketing activities chaperoning fund raisers.
Philippon: The biggest challenge for us is making sure we can understand and support as much as possible what is being said in the market and making it clear what agents can say under the regulations.
For that reason, we work very closely with agents, where applicable, to make sure that their messaging is aligned and understood.
Monson: The UK Financial Conduct Authority (FCA) is very strict on when you move from pre-marketing to marketing.
We have to be absolutely certain that our clients are only targeting professional clients.
And we have to have evidence of that.
NPPR vs passport — when does each win?
Cronje: It very much depends on the circumstances.
The National Private Placement Regime (NPPR) is ideal where it is an individual or a small number of Member States being targeted.
Under NPPR, you have to comply with the local jurisdictional rules and implementation of the AIFMD.
NPPR can be more cost effective, where the marketing is limited to certain individual EU Member States, if the marketing is planned to be across multiple EU Member States and broad based, then the NPPR would be inefficient and complex and in those circumstances the Passport offers significant advantages.
Philippon: Where there is a need to access a broad spectrum of EU investor capital, then passporting certainly offers a far better route, providing peace of mind, speed to market and is more cost-effective.
What aspects of the AIFM offering continue to appeal in the ESG space, and how do you support clients?
Lamotte: The regulatory requirements under Sustainable Finance Disclosure Regulation (SFDR) are complex, particularly in understanding the requirements under Article 8 and 9 — but a key play for us is the access we can offer through our AIFM platform to JTC’s central Sustainability and Impact Services team, which is increasingly feeding into managers’ ESG investment strategies.
Through them, we can help our clients with their gap analysis, strategy design, reporting and disclosure obligations.
Ultimately, it is all about taking the headache out of the regulatory requirements.
Cronje: Guernsey has been a pioneering jurisdiction for sustainable investment funds, with the Green Fund regime providing a regulated framework for trusted and transparent products with a positive environmental impact since its launch in 2018.
In recent years this has been complemented by the world’s first regulated Natural Capital Fund regime, which focuses on investments in biodiversity and nature.
This framework is well aligned with the European SFDR regulation and offers an alternative for fund promoters that are looking to launch sustainability and impact investment funds through a Non-EU route.
Our Non-EU Guernsey AIFM have been supporting and working with clients in the ESG space for many years and can help fund promoters navigate through the regulatory environment and enable them to focus on their core business.
With AIFMs in the UK, a non-EU Crown Dependency, and two EU fund heavyweights, does Brexit continue to be a factor for launching funds?
Monson: Brexit itself is not much of a factor anymore — navigating the different regimes that have emerged from Brexit is the main challenge.
The big issue is around passporting and that is where AIFM solutions come in — managers need optionality so that their strategies both within and outside of the EU can work seamlessly. I think JTC has got pretty much every avenue covered in that sense.
Looking to the future, what is changing under AIFMD II that managers will notice?
Lamotte: Under AIFMD II, our overall approach is to align delegation, risk, and reporting, so that compliance becomes a fundraising advantage, shortening time-to-first-close and raising confidence with institutional limited partners (LPs).
Philippon: A lot of the changes in Alternative Investment Fund Managers Regulations (AIFMD) II, which will come into play on 16 April 2026, relating to loan origination and credit strategies.
In Ireland, the AIFM currently does not manage these strategies. But should private credit activity continue to rise, then we could see more of an impact as we move into managing this asset class.
There are also changes around delegation — monitoring and oversight, expanded reporting and resourcing requirements when delegating investment management, for instance.
Are you seeing an increase in certain asset classes such as private assets?
Philippon: Our collective experience across our JTC Global AIFM Solutions team spans alternative and traditional asset classes, so we are well placed in that sense.
In Ireland specifically, although it has been a challenging fundraising market over the past year or so, we are seeing growth in private equity, and a slight uptick in real estate.
Monson: In London, we are still attracting a good volume of equities and equity derivatives.
Private equity and venture capital are showing some signs of growth, as well as real estate, but the listed activity remains strong.
Cronje: We continue to see a growth in private equity secondaries and private credit funds.
Real estate and infrastructure showing early signs of market improvement.
Our Guernsey AIFM is multi-asset disciplined and can support most asset classes, and although the fund raising environment is still challenging, we are beginning to see an uptick in most asset classes.
Simon Monson: Ultimately, the benefit of an Alternative Investment Fund Manager (AIFM) solution is to provide global fund managers with a cost-effective service that enables them to operate in compliance with regulatory requirements, by providing appropriate structures and good oversight.
From a UK perspective we are seeing a number of trends in this regard.
In particular, we are seeing a lot of activity in the ‘appointed representative’ programme in the UK whereby we take responsibility for regulating the UK manager entity.
It is a powerful proposition.
Orla Philippon: From an Ireland and wider EU viewpoint, the most obvious benefit an AIFM solution brings to managers is the marketing passport, enabling managers to seamlessly access EU investor capital.
That seamless and blanket access to investors across the EU is one of the key benefits.
Louis Lamotte: There is also an investor aspect.
Being able to provide high levels of investor protection through the strong governance credentials an AIFM solution can bring in stable jurisdictions, offers a great deal of reassurance to managers and of course their underlying investors.
Kobus Cronje:In Guernsey, the biggest advantage is that we are able to offer managers a cost-effective solution looking to market their funds either outside of the EU — including the UK — or to a small number of specific EU Member States.
The Guernsey AIFM solution offers a quicker route to market for non-EU fund promoters and carries a range of cost and flexibility advantages, without compromising on investor protection and the marketability of the funds outside of the EU and to targeted individual EU Member States.
How do you keep pre-marketing compliant but effective?
Lamotte: The differing interpretations of the term ‘marketing’ across Member States has been a consistent challenge since AIFMD was introduced – with new ‘harmonised’ pre-marketing regime brought into the AIFMD by the Cross-Border Distribution Framework (CBDF).
But it is still the case that pre-marketing is an activity that is more regulated than marketing itself.
You can delegate marketing of a fund to someone else, such as a general partner (GP), as long as you can demonstrate you have done proper due diligence.
But when it comes to pre-marketing, the delegation is more restricted — sometimes impossible — leading the AIFM to conduct the marketing activities chaperoning fund raisers.
Philippon: The biggest challenge for us is making sure we can understand and support as much as possible what is being said in the market and making it clear what agents can say under the regulations.
For that reason, we work very closely with agents, where applicable, to make sure that their messaging is aligned and understood.
Monson: The UK Financial Conduct Authority (FCA) is very strict on when you move from pre-marketing to marketing.
We have to be absolutely certain that our clients are only targeting professional clients.
And we have to have evidence of that.
NPPR vs passport — when does each win?
Cronje: It very much depends on the circumstances.
The National Private Placement Regime (NPPR) is ideal where it is an individual or a small number of Member States being targeted.
Under NPPR, you have to comply with the local jurisdictional rules and implementation of the AIFMD.
NPPR can be more cost effective, where the marketing is limited to certain individual EU Member States, if the marketing is planned to be across multiple EU Member States and broad based, then the NPPR would be inefficient and complex and in those circumstances the Passport offers significant advantages.
Philippon: Where there is a need to access a broad spectrum of EU investor capital, then passporting certainly offers a far better route, providing peace of mind, speed to market and is more cost-effective.
What aspects of the AIFM offering continue to appeal in the ESG space, and how do you support clients?
Lamotte: The regulatory requirements under Sustainable Finance Disclosure Regulation (SFDR) are complex, particularly in understanding the requirements under Article 8 and 9 — but a key play for us is the access we can offer through our AIFM platform to JTC’s central Sustainability and Impact Services team, which is increasingly feeding into managers’ ESG investment strategies.
Through them, we can help our clients with their gap analysis, strategy design, reporting and disclosure obligations.
Ultimately, it is all about taking the headache out of the regulatory requirements.
Cronje: Guernsey has been a pioneering jurisdiction for sustainable investment funds, with the Green Fund regime providing a regulated framework for trusted and transparent products with a positive environmental impact since its launch in 2018.
In recent years this has been complemented by the world’s first regulated Natural Capital Fund regime, which focuses on investments in biodiversity and nature.
This framework is well aligned with the European SFDR regulation and offers an alternative for fund promoters that are looking to launch sustainability and impact investment funds through a Non-EU route.
Our Non-EU Guernsey AIFM have been supporting and working with clients in the ESG space for many years and can help fund promoters navigate through the regulatory environment and enable them to focus on their core business.
With AIFMs in the UK, a non-EU Crown Dependency, and two EU fund heavyweights, does Brexit continue to be a factor for launching funds?
Monson: Brexit itself is not much of a factor anymore — navigating the different regimes that have emerged from Brexit is the main challenge.
The big issue is around passporting and that is where AIFM solutions come in — managers need optionality so that their strategies both within and outside of the EU can work seamlessly. I think JTC has got pretty much every avenue covered in that sense.
Looking to the future, what is changing under AIFMD II that managers will notice?
Lamotte: Under AIFMD II, our overall approach is to align delegation, risk, and reporting, so that compliance becomes a fundraising advantage, shortening time-to-first-close and raising confidence with institutional limited partners (LPs).
Philippon: A lot of the changes in Alternative Investment Fund Managers Regulations (AIFMD) II, which will come into play on 16 April 2026, relating to loan origination and credit strategies.
In Ireland, the AIFM currently does not manage these strategies. But should private credit activity continue to rise, then we could see more of an impact as we move into managing this asset class.
There are also changes around delegation — monitoring and oversight, expanded reporting and resourcing requirements when delegating investment management, for instance.
Are you seeing an increase in certain asset classes such as private assets?
Philippon: Our collective experience across our JTC Global AIFM Solutions team spans alternative and traditional asset classes, so we are well placed in that sense.
In Ireland specifically, although it has been a challenging fundraising market over the past year or so, we are seeing growth in private equity, and a slight uptick in real estate.
Monson: In London, we are still attracting a good volume of equities and equity derivatives.
Private equity and venture capital are showing some signs of growth, as well as real estate, but the listed activity remains strong.
Cronje: We continue to see a growth in private equity secondaries and private credit funds.
Real estate and infrastructure showing early signs of market improvement.
Our Guernsey AIFM is multi-asset disciplined and can support most asset classes, and although the fund raising environment is still challenging, we are beginning to see an uptick in most asset classes.
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