Key Dates & Deadlines: Q2 2025
The following are key dates and deadlines in Q2 2025 along with possible impacts and action items arising for fund managers.
| Date | Source | Summary | Action/Impact |
| Q2 2025 |  |
AIF Rulebook consultation The CBI expects to publish an AIF Rulebook consultation which would include AIFMD II transposition |
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| Q2 2025 |  |
ESMA CSA on sustainability disclosures ESMA expected to issue its report on the outcome of the CSA |
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| End Q2 2025 | |
Central Bank of Ireland ETF review Date by which fund management companies are required to incorporate any necessary changes to frameworks and practices in accordance with the requirements of the CBI letter on review of the ETF ecosystem |
Please see article on the topic in the December 2024 Update for further details |
| 2 April 2025 |  |
UK SDR naming and marketing rules End of temporary flexibility period for FCA 'naming and marketing' and disclosure rules |
Please see article on this topic in the November 2024 Update for further details. |
| 21 May 2025 | |
ESMA Guidelines on funds' names using ESG and sustainability related terms Funds in existence before 21 November 2024 must comply with the guidelines from this date. |
Please see article on topic in the September 2024 Update for further details |
| June 2025 |
Sustainable Finance omnibus simplification package Date by which the proposal delaying CSRD reporting for certain companies by 2 years and the effective date of CSDDD by 1 year ("stop-the-clock" proposals) is expected to come into effect at European level. |
Please see article on the topic in the March 2025 update for further details | |
| July 2025 | |
UCITS Eligible Assets Directive Issue of technical advice by ESMA on UCITS eligible assets has been delayed by 3 months to July 2025 |
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| 10 July 2025 | |
Consultation Paper on Fitness and Probity Regime Last day for submission of comments to the Central Bank |
Please see article on the topic in this update for further details. |
| 14 August 2025 | |
CBI Daily investment funds return Delayed go live date for Phase 2 reporting which focuses on data in relation to the use of liquidity management tools. |
Please see article on the topic in this update for further details. |
| Q4 2025 | |
SFDR update The European Commission's 2025 work programme has indicated that legislative changes to SFDR are scheduled for Q4 2025 |
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| October 2025 | |
Cross-border distribution ESMA's 2025 report on marketing requirements under the Regulation on cross-border distribution of funds has been delayed by 4 months to October 2025 |
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| 16 October 2025 | |
RTS on loan originating alternative investment funds Part of the AIFMD review, the release of these regulatory technical standards by ESMA will be delayed by 6 months to 16 October 2025 |
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| December 2025 | |
ECB Regulation on investment fund statistics including money market funds The first reporting under the European Central Bank Regulation on statistics on investment funds, including money market funds, will be with a reference date of December 2025 |
Please see article on the topic in the February 2025 update for further details. |
| 31 December 2025 | |
Sustainable Finance omnibus simplification package Date by which the European Commission has asked member states to implement the "stop-the-clock" proposals |
Please see article on the topic in the March 2025 update for further details. |
QIAIFs providing 3rd party guarantees: Central Bank of Ireland clarification
Irish funds authorised as QIAIFs are subject to the Central Bank of Ireland's (CBI's) Alternative Investment Fund Rulebook (Rulebook). The Rulebook provides that QIAIFs shall not grant loans or act as a guarantor on behalf of a third party. Although the term 'guarantor' is not defined in the Rulebook, it is commonly understood that QIAIFs cannot guarantee or provide security for the obligations of a third party.
On 7 March 2025 the CBI published a revised version of the AIFMD Q&A. The revised Q&A clarifies the application of the prohibition on AIFs acting as guarantors for third parties. The clarifications in the revised Q&A are particularly helpful in the context of fund finance transactions. QIAIFs can (subject to meeting certain conditions) provide direct guarantees and security for certain third-party obligations, offering a welcome alternative to complex cascading pledge arrangements. This also aligns the Irish regulatory position with other fund jurisdictions.
Further details
The specific Q&A's are set out below and you can read a more detailed William Fry article on this topic here.
Q&A ID 1160 confirms that guarantees are permissible in respect of investments and/or intermediate vehicles for such investments in which the QIAIF has a direct or indirect economic interest subject to a number of important safeguards and investor disclosures.
Q&A ID 1161 confirms that the definition of financial institution in the AIF Rulebook is aligned with that set out in the revised AIFMD loan origination rules which cross refers to EU Directive 2009/138/EC (Solvency II) that is transposed into Irish law through the European Union (Insurance and Reinsurance) Regulations 2015.
Q&A ID 1162 clarifies that the prohibition on lending to persons intending to invest in equities or other traded investments or commodities, does not prevent lending to a borrower with the intention of acquiring a controlling interest in a target company.
Daily investment funds return: Phase 2 timeline altered
Since 16 December 2024, the CBI has collected daily subscription and redemption data from all non-money market investment funds via the daily investment fund return (DIFR). The DIFR purports to replace the current daily and weekly trigger-based liquidity reporting. Daily subscription and redemption data was the first phase of daily investment fund returns. The next phase focuses on collection of data in relation to the use of liquidity management tools.
Timeline altered
Following industry engagement, the original go-live date of 2 June 2025 has been postponed to 14 August 2025.Prior to this, revised templates will be circulated, there will be a 6-week testing window and time to provide and assess feedback from the testing process.
Standards for Business Regulations
The Standards for Business Regulations were published on 25 March 2025 under the Central Bank Reform Act 2010. These regulations aim to enhance the conduct and governance standards for regulated financial service providers in Ireland. They will come into force on 24 March 2026. The Regulations have been long anticipated, as they form a constituent part of the Conduct Standards provided for under the Individual Accountability Framework (along with the Common Conduct Standards and Additional Conduct Standards for persons occupying CF roles).
Who must apply the Standards?
A regulated financial service provider is an entity authorized to conduct financial services activities under the Central Bank Act 1942. This includes fund management companies, externally managed corporate funds and fund service providers authorised and regulated by the CBI.
Requirements of the standards
The standards set out governance, resource, and risk management requirements for all regulated firms from 24 March 2026. They also set out Standards for Business which are conduct standards for firms. These are complemented by Supporting Standards for Business which provide further detail on firms' obligations. The specific Standards for Business and Supporting Standards for Business which address (i) securing customers' interests and (ii) financial abuse, will only apply to firms when doing business with individuals and small businesses (consumers). All other Standards for Business and Supporting Standards for Business will apply to the regulated business of firms conducted with all customers.
Next steps
Firms should analyse the requirements of the standards to understand what action may need to be taken to comply with the requirements by 26 March 2026.
Delays to ESMA mandates
ESMA issued a letter dated 3 March 2025 to the European Commission setting out details of prioritisation and delays to several mandates which it was due to deliver in 2025 under its work programme. The delays affect ongoing workstreams for the AIFMD review, EMIR, Listing Act, MiFIR/D review and UCITS Eligible Assets. For example, the release by ESMA of guidelines to specify the circumstances in which the name is unfair, unclear or misleading will be delayed by at least 12 months from the original date of 16 April 2026. Other dates relevant for investment funds are set out in the Key Dates & Deadlines section of this update.
Consultation Paper on Fitness and Probity Regime
On 10 April 2025, the CBI issued a Consultation Paper on proposed amendments to its Fitness and Probity Regime, including its Guidance.
This Consultation Paper (CP160) addresses the 2024 Enria review recommendations for increased clarity and transparency of supervisory expectations in relation to the application of the CBI's Fitness and Probity Standards and includes a review of the list of prescribed pre-approval controlled functions (PCFs).
The revised Guidance incorporates high-level expectations in relation to:
- inherent responsibilities, and role summaries, of certain PCFs
- time commitments of specific PCFs
- level of experience required for specific PCFs and
- level of knowledge/qualifications required for specific PCFs.
The CBI has focused on executive, non-executive, independent non-executive directors, and heads of the control functions, given the importance of these roles. The expectations are set out in Chapter 4 of the draft Guidance and predominantly emanate from existing requirements, standards or guidance, or are reflective of existing best practice
Submissions to the consultation can be made until 10 July 2025.
Submissions to the consultation can be made until 10 July 2025.
The CBI has indicated that it intends to commence industry engagement in 2025 with a focus on management companies and their use of the delegation model. The first half of this year will focus on third party management companies and other management companies to follow. There is likely to be a 12 to 18 month engagement process.
SEC guidance restricting corporate engagement in the US
The US SEC in February 2025 updated guidance that will restrict asset managers' ability to engage with US investee firms. This is relevant for investment funds with exposure to US corporates. The revised rules impact engagement generally and will, in particular, impact engagement with US firms on ESG issues.
Beneficial ownership reporting
An update to an SEC compliance and disclosure interpretation prevents investors from conducting ordinary investor engagement unless they are willing to bear additional beneficial ownership reporting requirements.
In particular the SEC states that where investors i) undertake specific actions on a social, environmental, or political policy and, as a means of pressuring the issuer to adopt the recommendation, explicitly or implicitly conditions its support of one or more of the issuer's director nominees, and ii) discuss with management its voting policy on a particular topic and how the issuer fails to meet the shareholder's expectations on such a topic this may constitute attempts by the investor to "influence control" over a company. This could result in the investor being classified as an active, rather than a passive, investor and trigger a longer beneficial ownership filing with the SEC.
SEC "no-action relief" and excluding shareholder proposals
Where shareholders petition a US company to include a topic for vote on the annual proxy statement, the management of a US company can request a "no-action relief" from the SEC to not include the topic. Usual grounds on which the SEC will grant the relief are i) the 'economic relevance' exclusion and ii) the 'ordinary business' exclusion. The SEC has provided clarifications that will make it easier for company management to exclude proposals on these grounds.
The SEC clarified that shareholder proposals raising social or ethical issues should demonstrate that to be economically relevant, these issues would have "a significant effect on the company's business". It is insufficient to state that these issues could result in reputational or economic harm to the company.
The SEC also clarified that stakeholder proposals can only raise social policy issues when the issue is significant for the company rather than for society. The board no longer needs to provide the SEC with an assessment of whether a proposal raises a significant issue.
The SEC clarified that it would bar proposals requiring granular disclosures or imposing specific timeframes or methods for implementing the company's policies, for example, proposals related to transition plans or complex policies to set senior executive and/or director compensation.
EU Savings and Investment union
In March 2025, the European Commission unveiled its strategy for the Savings and Investment Union (SIU), a significant initiative aimed at enhancing the EU financial system's ability to channel savings into productive investments. This strategy is particularly relevant for the asset management and investment funds sector, as it introduces several measures designed to foster a more integrated and competitive financial market.
Main points
1. Enhanced Retail Participation
The SIU strategy emphasizes increasing retail investors' participation in capital markets. By providing broader investment options and improving financial literacy, the initiative aims to encourage EU citizens to invest more of their savings in higher-yielding capital market instruments rather than traditional bank deposits. This shift is expected to create new opportunities for asset managers and investment funds to attract retail investors.
2. Improved Access to Capital for Businesses
The strategy includes measures to improve the availability and access to capital for businesses, particularly small and medium-sized enterprises (SMEs). By facilitating easier access to financing, the SIU aims to support business growth and innovation, which in turn can create more investment opportunities for funds focusing on SMEs and emerging companies.
3. Integration of Capital Markets
A key component of the SIU is the further integration of EU capital markets. The strategy seeks to create a more unified and efficient market, making it easier for asset managers and investment funds to operate across borders, including removing barriers to cross-border distribution of EU-authorised funds. This integration is expected to reduce barriers and increase the competitiveness of the EU financial market. Simplification of operations of asset managers is a goal. The EC will also propose measures to strengthen convergence tools. Large cross-border asset management groups are specifically mentioned for consideration of supervision at EU rather than domestic level.
4. Support for Sustainable Investments
The SIU strategy aligns with the EU's broader goals of digital and green transitions. It includes initiatives to promote investments in sustainable projects, providing asset managers and investment funds with opportunities to develop and offer green investment products. This focus on sustainability is expected to attract investors who are increasingly looking for environmentally responsible investment options.
5. Regulatory Enhancements
To support these initiatives, the SIU strategy also involves regulatory enforcement enhancements aimed at protecting investors and ensuring market stability. These regulatory measures are designed to build investor confidence and create a safer investment environment, benefiting both asset managers and their clients.
Timing of Proposals and Next Steps
The SIU strategy was officially announced on March 19, 2025. The European Commission has outlined a phased approach to implementing the proposals, with initial measures expected to be rolled out throughout 2025. Key stakeholders, including EU institutions, member states, and industry participants, will collaborate to refine and execute the strategy. The next steps involve detailed planning and consultation to ensure the effective integration of the proposed measures, with a focus on the most impactful actions first.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
