Changes in AIFMD Reporting to the FIN-FSA

Authors: Jari Tukiainen (Specialist Partner), Tiia Mäki (Associate), and Emma Ahonen (Associate Trainee)

The FIN-FSA’s Reporting System Under Reform

The Finnish Financial Supervisory Authority (the “FIN-FSA”) is reforming its reporting system. There are several key changes introduced with the reform. The system reform covers EBA ITS, EIOPA ITS, ESMA, and national (Virati) regulatory reporting, including AIFMD and short selling reporting (see our previous blog post Upcoming Changes in the Notification Process of Net Short Positions to the Finnish Financial Supervisory Authority).

Until the reform, alternative investment fund managers (“AIFMs”) were able to submit AIFMD reports to the FIN-FSA via email. As of 30 September 2023, AIFMs must submit their reports via a new system.

Access to the New Reporting Portal Requires Action

A person (with a Finnish personal identity number) authorised to sign on behalf of a Finnish AIFM may report directly on behalf of the AIFM or grant mandates to employees or other entities (service providers), for example, by logging into the Suomi.fi e-Authorisations webpage, where electronic authorisations can be granted and requested.

Reporting entities without a Finnish business ID (in Finnish: Y-tunnus) must authorise persons to act on their behalf by filling in a mandate application on the Suomi.fi Authorisation with an application webpage and submitting the application to the Digital and Population Data Services Agency. If the person authorised to report on behalf of an AIFM does not have a Finnish personal identity number, registration via the Finnish Authenticator Identification Service is required. It should be noted that the processing of the mandate application and its attachments may take some time, as postal delivery of the documentation is required in some cases.

Functionalities of the New Reporting Portal

Each reporter can see their own reporting obligations in the new reporting portal, where reporters can either upload reports they have produced themselves or complete data collection-specific web forms. Submitting reports directly to the FIN-FSA will also be possible using the reporter’s own reporting system via a provided interface (A2A).

After submitting a report, reporters will receive feedback via the new reporting portal and the interface (A2A) directly into the reporter’s own reporting system. Reporters can also download submitted reports and reporting feedback in Excel format.

Test Environment

Reporters have access to a test environment, where they may submit reports for review before submitting the official report to the FIN-FSA. The test environment allows reporters to receive automatic feedback on possible form errors in their reports and possible breaches of the EBA and EIOPA Filing Rules. It is also possible to receive feedback on incorrect validations.

Production of the FIN-FSA’s Own Reporting Applications Ends

The production of the FIN-FSA’s previous reporting applications will end as reporting is transferred to the new reporting system.

No Transitional Period

No transitional period has been announced by the FIN-FSA, wherefore reports should be submitted to the new system as of the dates indicated on the FIN-FSA’s website.