Germany's Federal Financial Supervisory Authority consults on revised guidance to streamline AIFM authorisation procedures under the Investment Code

Germany's Federal Financial Supervisory Authority (BaFin) has published draft amendments and clarifications to its guidance on the authorisation process for an alternative investment fund capital management company (AIFM) under section 22 of the German Investment Code (KAGB), with the stated aim of easing and speeding up licensing procedures. The draft revises and specifies expectations in areas including evidence of own funds required for business operations (section 25 KAGB), information used to assess the professional suitability of managing directors, the content of the business plan and organisational set-up (including how the AIFM will meet its legal obligations), the required fund and corporate documentation for the AIFs to be managed and for the AIFM itself, and clarifications on when authorisation is required and whether authorisation can be granted. Comments on the draft are due by 30 September 2025. BaFin plans to publish submissions online and has asked respondents to indicate if they object to publication or onward sharing; it also intends to transfer the finalised fitness and propriety clarifications into its separate guidance on the suitability of managing directors under the KAGB after the consultation closes.