Germany's Federal Financial Supervisory Authority has launched a consultation on a draft circular explaining changes to the Capital Investment Code introduced by the Fund Risk Limitation Act. The draft guidance is meant to clarify rules that took effect on April 16, 2026, with the main areas covering mandatory liquidity management tools for open-ended funds, changes to authorization procedures and lending by investment funds. A central element is the requirement for open-ended investment funds to embed at least two liquidity management tools in their liquidity management systems. The circular sets out general expectations for those tools and addresses the specific features of each tool. It also explains changes to the authorization process, including additional information requirements relating to managing directors, and the removal of the linkage between financial portfolio management and investment advice or the brokerage of financial instruments as ancillary services to collective asset management. A final section covers the revised framework for lending by investment funds. Comments on the draft are invited until July 6, 2026.

Original source Back to tracker