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Annex IV, fund data, and investor questions, out of three different systems. We put them in one.

An AIFM's Annex IV filing pulls from the fund accounting system, the delegation record lives in a compliance file, and when an investor asks a due-diligence question, someone assembles the answer from all three by hand. Our platform now holds the fund data itself, cash events, commitments, NAV observations, and portfolio holdings, generates the AIFMD Annex IV submission as validated XML from that data, and gives investors a trust portal to see governance and reporting status directly. DORA runs on the same delegate and supplier records. Where AIFMD calls for judgement, substitutability, exit planning, delegation substance, our specialists work from that same data, with support built into the platform around it.

Regulatory perimeter DORA · AIFMD · UCITS
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Supervisor AFM / DNB (NL) · ESMA (at EU level)
The problem

The Annex IV filing, assembled by hand, every quarter.

An AIFM's Annex IV filing needs fund data from the administrator, delegation information from compliance, and risk figures that may live in a third system entirely. Most firms rebuild that filing from scratch each reporting period, reconciling numbers across systems that were never designed to talk to each other, under a deadline that does not move.

The delegation chain compounds it. Portfolio management delegated to an affiliate, administration to a third party, depositary to a credit institution: AIFMD Article 20 requires the ManCo to retain substantive oversight, not become a letterbox. DORA treats the same delegates as ICT third parties, with a different criticality test. The administrator that AIFMD calls a delegate, DORA calls an ICT service provider, and most firms keep two separate registers for what is, functionally, one relationship.

Investors add a third pressure. Due-diligence questionnaires ask for governance evidence, reporting status, and delegation detail that someone currently assembles from the same scattered sources, on the investor's timeline rather than the fund's.

What changes

The fund data lives here. Annex IV is a submission, not a rebuild.

The platform now holds fund-level data directly: cash events, commitments, NAV observations, and portfolio holdings. The AIFMD Annex IV submission is generated from that data as validated XML, not reassembled from separate spreadsheets each period. The same delegate, an administrator or a portfolio manager, is a single supplier object referenced by both the DORA Register of Information and the AIFMD delegation view, so a contract amendment updates both.

Investors get a trust portal into the platform: governance status, reporting state, and the delegation structure, visible directly rather than reconstructed on request. That is the same underlying data the Annex IV filing and the DORA register draw from, presented for an investor audience.

What this does not claim: the platform does not decide whether a delegation arrangement preserves substantive oversight, or whether a delegate is substitutable. Those are AIFMD judgement calls, and they stay with our specialists, working from the same fund and delegate data the platform now holds, with support built into the platform to keep that work attached to the record it concerns.

What the platform takes over

Fund administration, Annex IV, the trust portal, and DORA.

When a ManCo is onboarded, the platform activates fund administration: cash events, commitments, NAV observations, and portfolio holdings as first-class records, feeding a regulatory reporting module that produces the AIFMD Annex IV submission as validated XML. The DORA Register of Information runs across all fifteen RT/B tables from the same delegate and supplier data, with GLEIF/LEI verification and a submission-ready XBRL-CSV package.

The stakeholder and investor trust portal gives limited partners and other stakeholders direct visibility into governance and reporting status, drawn from the same records rather than a document prepared separately for each request. Supplier risk, governance and role structures, and the core workflow engine with its four-eye approval gate sit underneath all of it.

Our specialists carry AIFMD interpretation, delegation substance under Article 20, depositary oversight, and the AIFMD II transposition reading ahead of the April 2026 deadline, working from the fund and delegate data the platform now holds rather than reassembling it. UCITS delegation and depositary obligations follow the same pattern for firms that also run retail funds.

Where specialists carry the judgement

Substitutability and substance stay judgement calls.

Whether a delegate can be replaced without disrupting the fund, whether oversight of a delegated function is substantive enough to avoid the letterbox test, and how AIFMD II's tightened delegation-substance requirements should be read ahead of the 2026 transposition deadline: none of that is a data question the platform answers on its own. Our specialists, former AFM supervisors and former ManCo compliance and risk officers among them, make that call, and the fund and delegate data in the platform is their starting point rather than something they rebuild.

The decision is recorded against the delegate record it concerns, so the reasoning behind a substitutability assessment or an exit-plan judgement is attached to the same object the Annex IV filing and the DORA register reference, not filed away separately.

You own the platform, the fund and delegate data as adapted to your operation, and the written record of every interpretation decision. Advisory work continues on delegation substance and depositary oversight for as long as you need it.

Next step

A discovery call, not a product demo.

You describe the compliance problem consuming the most of your team's time. We walk the platform through an example close enough to your operation that you can judge whether this way of modelling compliance fits how you want to work.

Book a discovery call →