The Dutch AIFM Light regime continues to gain traction among fund managers. It offers a simplified registration pathway for those managing less than €100 million in assets, or €500 million in the case of closed-end unleveraged funds. For smaller teams or first-time managers, it provides a faster route to market.
However, the Dutch Authority for the Financial Markets (AFM) has made it clear that a lighter regime does not imply lower standards. With total assets under AIFM Light now approaching €26 billion, the regulator is increasing its level of scrutiny. Compliance is no longer just about documentation. It is about execution, oversight, and operational readiness.
1. Written Policies Are Not Enough
Having policies on file is only the starting point. The AFM expects to see that compliance processes are actually in use and consistently followed.
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Know-Your-Customer (KYC) and Anti-Money Laundering (AML) checks must be integrated into the onboarding workflow and applied to every investor.
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If a fund manager delegates parts of the process to third parties, such as administrators, the responsibility remains with the manager. Internal teams must be equipped to oversee and validate external work.
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This includes proper handling of investor risk scoring, source of funds checks, and enhanced due diligence where required.
These expectations apply to all managers operating under the AIFM Light regime, regardless of size or complexity.
2. Investor Classification Must Be Accurate and Defensible
Incorrect investor classification is one of the most common issues flagged during AFM reviews. AIFM Light managers are only permitted to onboard professional investors.
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Individuals, even those with significant wealth or experience, do not qualify as professional investors under this regime.
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If retail investors are admitted under a different legal structure or exemption, they must be provided with a Key Information Document (KID) before committing capital.
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When relying on the 150-person exemption, managers must track how many individuals were approached, not only how many invested.
The classification process must be consistent, clearly documented, and backed by reliable data.
3. Ongoing Obligations Are Part of the Regime
AIFM Light simplifies initial registration, but it does not remove the need for continuous compliance.
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Managers must file annual reports covering financial instruments, risk concentrations, and exposures.
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Any changes to the firm’s structure, governance, or activities must be reported promptly to both the AFM and investors.
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If a fund manager stops operating, they are required to formally deregister with the regulator.
These obligations are not optional. They are part of maintaining registration and avoiding regulatory risk.
4. AFM Oversight Is Increasing
The AFM’s most recent sector letter reinforces that AIFM Light is no longer viewed as a marginal regime. It now represents a significant portion of the Dutch funds market, and the regulator is responding accordingly.
Increased attention is being placed on:
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The operational execution of AML and KYC frameworks
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The accuracy of investor documentation and classification
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The quality of oversight when services are outsourced
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The timeliness and completeness of reporting
Managers operating under AIFM Light must be prepared to demonstrate control across all of these areas.
5. Leading Managers Are Moving to Structured Compliance Infrastructure
Fund managers who plan to scale within or beyond the AIFM Light regime are investing in stronger systems to reduce operational risk and maintain regulatory confidence.
These firms are:
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Unifying onboarding, identity checks, and document collection in a single workflow
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Automating enhanced due diligence prompts based on risk signals during onboarding
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Ensuring investor data and documentation are accessible in one secure location
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Building a permanent audit trail that is ready for regulator or investor review at any time
This type of structure provides more than compliance. It enables faster onboarding, higher-quality data, and better collaboration across legal, compliance, and investor relations teams.
How Mesh ID Supports AIFM Light Managers
Mesh ID provides the infrastructure fund managers need to meet regulatory expectations while reducing the manual burden on their teams.
Our platform includes:
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Configurable onboarding workflows aligned with Dutch AML and AFM expectations
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Real-time enhanced due diligence that adapts to investor responses
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A secure investor portal with live status updates and data collection
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Automated audit trails and reporting tools for full transparency
Whether you are onboarding institutional investors or working with a lean internal team, Mesh ID ensures that compliance does not slow your fund’s momentum.
Final Thought
The AIFM Light regime offers real advantages for emerging and growth-focused fund managers. It lowers the barrier to entry, but it does not lower the bar for compliance. As regulatory expectations increase, teams need to show that policies are embedded in day-to-day operations, that investor onboarding is structured and risk-based, and that documentation is complete, timely, and audit-ready.
This is where Mesh ID becomes critical.
By centralising onboarding, identity verification, and enhanced due diligence in a single workflow, Mesh ID helps managers avoid fragmented processes that lead to compliance gaps. Our platform reduces the manual effort required to stay aligned with AFM expectations, while giving teams clear visibility across every investor file, every document, and every risk signal.
Compliance becomes faster, cleaner, and far more scalable — without adding headcount or complexity.
For fund managers operating under the AIFM Light regime, this level of infrastructure is no longer optional. It is the foundation for both regulatory readiness and operational resilience. Mesh ID is built to deliver exactly that.