Read the CySEC Circular C743
Memo #66-2025
CySEC Circular No: C743
Date: 22/12/2025
Subject: Application of the requirement of the Directive (EU) 2024/927 in relation to liquidity management tools - Amendment of the regulations, constitutional documents, or partnership agreement of open-ended AIFs and UCITS (in Greek)
Purpose: To inform Regulated Entities that the Directive (EU) 2024/927 is issued which amends Directives 2011/61/EU and 2009/65/EC as regards delegation arrangements, liquidity risk management, supervisory reporting, the provision of depositary and custody services and loan origination by alternative investment funds.
In Summary:
CySEC has issued the Circular C743 on 1912/2025 to inform the UCITS Management Companies, UCITS that have not appointed a Management Company (internally managed UCITS), Alternative Investment Fund Managers (AIFMs) managing open-ended AIFs, and AIFMs that are internally managed open-ended AIFs that the “Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024 amending Directives 2011/61/EU and 2009/65/EC as regards delegation arrangements, liquidity risk management, supervisory reporting, the provision of depositary and custody services and loan origination by alternative investment funds” is issued.
Directive (EU) 2024/927 introduces, in Annex V of the AIFMD and Annex IIA of the UCITSD respectively, a harmonised list of the nine (9) liquidity management tools set out below:
1) Suspension of subscriptions, repurchases and redemptions
2) Redemption gate
3) Extension of notice periods
4) Redemption fee
5) Swing pricing
6) Dual pricing
7) Anti-dilution levy
8) Redemption in kind
9) Side-pockets
Circular C743 refers to important amendments that Regulated Entities need to address.
The CySEC urges the Regulated Entities to take the necessary steps to amend the regulations, constitutional documents or partnership agreement of open-ended AIFs and UCITS, so that, from 16/04/2026, they comply with the obligations laid down in Articles 1(8) and 2(6) of Directive (EU) 2024/927, which will be transposed into national law.
Circular C743 also refers to relevant applications/notifications that Regulated Entities need to submit, accordingly, by 27/02/2026. The relevant applications/notifications need to be accompanied by specific documents, as those are explained in detail with Circular C743.
Directive (EU) 2024/927 can be found on the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202400927
Read the CySEC Circular C743
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