Mandatory XML Format for Annex IV Reporting

Finanstilsynet NO News

Published December 12th, 2025

Detected March 18th, 2026

Summary

Finanstilsynet (Norway) will mandate the use of XML format for Annex IV reporting for Alternative Investment Fund Managers (AIFMs) starting June 30, 2026. This change replaces the current manual Altinn form submission to enhance automation and standardization.

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What changed

Finanstilsynet has announced that effective June 30, 2026, all Annex IV reporting for both registered and authorized AIFMs, including those marketing AIFs in Norway from outside the EEA, must be submitted exclusively in XML file format. This transition marks the discontinuation of the manual Altinn forms, which will be phased out by June 1, 2026, with the existing reporting solution also being discontinued on the same date. The new requirement aligns with ESMA's technical specifications and aims to facilitate automation and standardization in regulatory reporting.

Affected entities, primarily fund managers, must prepare to adopt the XML format for reporting reference dates from June 30, 2026, onwards. This includes uploading an XML file for each AIF and AIFM. Managers who have not previously used the XML solution are strongly encouraged to begin preparations immediately. Finanstilsynet will provide updated guidance on its website. Non-compliance with the new format by the deadline could lead to reporting deficiencies.

What to do next

Review ESMA's updated technical guidance (revision 6) for Annex IV reporting.
Prepare systems and processes to generate and submit Annex IV reports in XML format.
Ensure all Annex IV reports are submitted in XML format by the June 30, 2026 deadline.

Source document (simplified)

Mandatory xml format to be introduced for Annex IV reporting from 30 June 2026

News

Published: 12 December 2025 Finanstilsynet hereby announces an important change in the reporting format for Annex IV reporting under the AIF Act and AIFMD (Directive 2011/61/EU on the regulation of alternative investment fund managers).

With effect from 30 June 2026, it will be mandatory for both registered AIFMs and authorised AIFMs to report Annex IV to Finanstilsynet using xml file attachments. This also applies to managers that are established outside the EEA and authorised to market their AIFs in Norway.

Background

Annex IV reporting for AIFMs was introduced as part of the AIF legislation in 2013. Until now, AIFMs have been able to use customised Altinn forms that can be filled in manually. The forms have been improved several times.

Since 2020, Finanstilsynet has offered a parallel solution where reports are submitted via xml file attachments. This solution has gradually been adopted by several AIFMs.

The system for Annex IV reporting is complex, and in connection with the phasing out of the Altinn II platform and the transition to Altinn 3, Finanstilsynet has decided not to develop new Altinn forms for this reporting. Mandatory use of xml reporting facilitates automation and standardisation.

What are the changes?

With effect from the reporting with reference date 30 June 2026, all Annex IV reporting must be carried out using xml file attachments. This applies to:

KRT-1161 – AIFM reporting
KRT-1160 – AIF reporting From 1 June 2026, the existing reporting solution will be discontinued. From this date, all new outstanding reports and corrections to reports submitted previously must be delivered as xml file attachments to new, simple Altinn forms. The new Altinn solution will mean that an xml file must be uploaded for each AIF and for each AIFM. The solution will be the same as the current reporting using xml format.

Technical requirements

The reporting shall follow ESMA's technical specifications. Finanstilsynet refers to the updated technical guidance from ESMA (revision 6), which contains mandatory fields and structural requirements for the xml format. The guidance can be found here:

ESMA AIFMD Reporting IT Technical Guidance Rev. 6

Guidance and support

Finanstilsynet will update its website with relevant information and guidance for xml reporting. AIFMs who have not previously used the xml solution are encouraged to start preparations well in advance.

If you have any questions, please contact us by e-mail: AIFMD-rapportering@finanstilsynet.no