Introduction
Welcome to the Q1 2025 edition of the Global Registration Services Market Update, brought to you by the Maples Group. This briefing covers the period from January to March 2025 and provides an overview of the latest regulatory changes and fee adjustments affecting the cross-border distribution of investment funds.
Key updates from multiple jurisdictions including across Europe, Middle East and Asia Pacific are highlighted, with important topics flagged for your attention.
Our aim is to keep you informed of the evolving regulatory landscape related to the cross-border marketing of funds to ensure your compliance and strategic planning are well-supported. We trust you will find this update insightful and beneficial for your ongoing operations.
How the Maples Group Can Help
The Maples Group's Global Registration Services is integrated within our Funds & Investment Management Group and provides cross-border fund registration services in all key distribution markets. Our core services provide support throughout the distribution chain to include market intelligence, market entry (through private placement or public offering) and maintenance of ongoing reporting and filing obligations.
Further Information
Should you require any further information or assistance in relation to marketing your fund products on a cross-border basis, please visit our dedicated webpage or contact the following or any member of the Maples Group GRS team
Contacts
Dublin
Emma Conaty
Head of Global Registration Services
emma.conaty@maples.com
Acknowledgements
We greatly acknowledge the contribution of Emma Hanway to this quarter's Update.
Important items occurring outside of this update
Isle of Man
Regulatory Fees and Charges Levied in Relation to Recognised Foreign Funds
On 1 April 2025, the Isle of Man Financial Services Authority ("IOMFSA") communicated its 2025 fees and charges. The table below summarises those updated fees and charges compared to the previous year.
| Fund Category | Fund Type | Amount applicable in 2024 | Amount applicable in 2025 |
| Designated Territory (Jersey, Guernsey, UK, Luxembourg and Ireland) | All Fund Types |
Initial Market Entry Fee: £3,060 per Fund Periodic Fee: £1,301 per Fund |
Initial Market Entry Fee: £3,121 per Fund Periodic Fee: £1,561 per Fund |
| Non-Designated Territory | Single Structure Funds |
Initial Market Entry Fee: £6,120 per Fund Periodic Fee: £4,335 per Fund |
Initial Market Entry Fee: £6,242 per Fund Periodic Fee: £5,202 per Fund |
| Umbrella Funds |
Initial Market Entry Fee: £5,610 per Fund and £1,530 per Sub-Fund Periodic Fee: £4,335 per Fund and £867 per SubFund |
Initial Market Entry Fee: £5,722 per Fund and £1,561 per Sub-Fund Periodic Fee: £5,202 per Fund and £1,040 per Sub-Fund |
United Kingdom
New Consultation on Alternative Investment Funds
On 7 April 2025, His Majesty's Treasury ("HM Treasury") opened a new consultation to propose amendments to the regulations governing managers of Alternative Investment Funds ("AIFs"). The initiative aims to streamline regulations, making it simpler and more cost-effective for asset managers to operate within the UK.
The consultation suggests simplifying the existing regulatory framework for Alternative Investment Fund Managers ("AIFMs"), with a focus on maintaining essential consumer and market protections while reducing complexity. It is proposed to remove detailed, firm-facing requirements from the legislation to align with the UK's established model for financial services regulation.
The Financial Conduct Authority ("FCA") also published a Call for Input in conjunction with the HM Treasury consultation paper which aims to provide stakeholders with clarity regarding the direction of reforms and offers an opportunity for feedback before the FCA proceed with the development of detailed rules and guidance for further consultation.
The consultation and the Call for Input paper are both open for response by AIFMs and Stakeholders until 9 June 2025.
Q1 2025 Updates
Europe
In addition to those reported in our Q4 2024 Market Update, a number of other national competent authorities introduced revised regulatory fees with effect from 1 January 2025 as further outlined below.
Belgium
Regulatory Fees and Charges Levied in Relation to Cross-Border Marketing of UCITS and AIFs
On 11 February 2025, the Financial Services and Markets Authority ("FSMA") communicated its 2025 fees and charges levied for carrying out its duties in relation to marketing of foreign UCITS and AIFs in Belgium. The table below summarises those updated fees and charges compared to the previous year.
| Registration fee / annual contribution payable by foreign UCITS / AIFs | Amount applicable in 2024 | Amount applicable in 2025 |
| Registration fee for the marketing of an UCITS to the public | EUR 471 (per subfund/compartment) | EUR 505 (per subfund/compartment) |
| Annual contribution for an UCITS authorised for marketing as of 1 January | EUR 3,222 (per subfund/compartment) | EUR 3,452 (per subfund/compartment) |
| Registration fee for the marketing of an AIF to the public | EUR 471 (per umbrella fund / stand-alone fund) | EUR 505 (per umbrella fund / stand-alone fund) |
| Annual contribution for a selfmanaged EEA AIF authorised for marketing to the public as of 1 January | EUR 586 (per umbrella fund / stand-alone fund) | EUR 628 (per umbrella fund / stand-alone fund) |
| Annual contribution for a selfmanaged third-country AIF authorised for marketing to the public as of 1 January |
Depends on the value of AUM over the previous year:
|
Depends on the value of AUM over the previous year:
|
| Annual contribution for a selfmanaged third-country AIF authorised for marketing to professional investors as of 1 January | EUR 586 (per umbrella fund / stand-alone fund) | EUR 628 (per umbrella fund / stand-alone fund) |
| Annual contribution for an AIF authorised for marketing to the public as of 1 January | EUR 20,125 (per subfund/compartment; double in the first year the contribution is due) | EUR 21,562 (per subfund/compartment; double in the first year the contribution is due) |
France
AMF Reporting on Non-Financial Criteria
Making reference to our recent client update, "AMF Reporting on Non-Financial Criteria" , the Autorité des Marchés Financiers ("AMF") published an amendment of the AMF Position-Recommendation DOC-2020-03 on 30 December 2024,
This Position Recommendation details a new platform launched by the AMF in March 2024 called ROSA, for the filing of non-financial criteria by French managers and non-French managers who manage French funds.
Until the publication of this Position Recommendation, those managers of UCITS approved for crossborder marketing in France who were utilising non-financial criteria as a key aspect of their marketing communications were required to submit an ESG Notification Form (Annex XX to AMF Position 2011- 19) to the AMF.
Now French managers are required to file through ROSA while non-French managers of UCITS approved to market on a cross-border basis are required to submit a new Excel matrix to the AMF via email. Following transmission of the marketing notification file by the UCITS home national competent authority, the AMF will provide a copy of this Excel matrix directly to the contact identified in the UCITS notification letter. The AMF intends to extend access to the ROSA platform to all non-French managers in the future, however, the timeline for this expansion is currently unclear.
Germany
Changes to the Investment Ordinance
On 6 February 2025, the German Federal Law Gazette published the announcement of significant amendments to the Investment Ordinance ("AnlV") which have been implemented through the Eighth Ordinance to Amend Ordinances under the Insurance Supervision Act. These changes entered into force on 7 February 2025 and are particularly relevant for pension schemes, funeral funds, small insurance companies, and occupational pension schemes.
The key changes to AnIV will include:
- a facilitation of infrastructure investments by introducing a new relief quota which will allow up to 5% of restricted assets to be used for infrastructure investments without being counted towards the investment limits.
- an expansion to the risk capital quota which will see an increase from 35% to 40% on restricted assets.
- a change to the opening clause which has been expanded to allow investments that exceed diversification limits pursuant to § 4 para 1 – 4 AnIV to be included.
- clarification for private equity funds where shares or stocks in Public-Private Partnership project companies and infrastructure project companies are now explicitly recognised as eligible assets.
Guernsey
Consultation Paper on the Prospectus Rules
On 6 January 2025, the Guernsey Financial Services Commission ("GFSC") released a consultation paper on a proposed set of rules relating to the issuance of prospectuses in respect of Category 2 Controlled Investments and Collective Investment Schemes which are registered under Section 8 of the Protection of Investors (Bailiwick of Guernsey) Law, 2020 ("the POI Law").
The proposed changes will include enhancements to the disclosure requirements to ensure that investors receive comprehensive and clear information about the securities being offered, revisions to the eligibility criteria for issuers to ensure that only entities meeting high standards can issue prospectuses, a streamlining to the approval process for prospectuses to make it more efficient while maintaining rigorous standards and strengthening compliance and enforcement mechanisms to deter and address breaches of the Prospectus Rules.
The consultation paper closed on 3 March 2025, with further updates to follow pending a review and consideration by the GFSC.
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