Key data
| Regulation | Corrigendum to Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024, amending Directives 2011/61/EU (AIFMD) and 2009/65/EC (UCITS) |
|---|---|
| Publication | 22 July 2026 |
| Entry into force | Not specified in the corrigendum |
| Affected parties | Alternative investment fund managers (AIFM) and UCITS fund managers in the European Union |
| Category | European Regulation |
| Amended Directives | Directive 2011/61/EU (AIFMD) and Directive 2009/65/EC (UCITS) |
| Official source | EUR-Lex — OJ:L_202690614 |
Alternative investment fund managers and UCITS fund managers operating in the European Union have a new mandatory reference text: the corrigendum published on 22 July 2026 corrects formal inaccuracies in Directive (EU) 2024/927, approved on 13 March 2024. This original directive already introduced significant changes in five major areas of the regulatory framework for asset management in Europe. Although the corrections are technical in nature and do not modify the substance of the regulation, working with a text containing formal errors can generate interpretation and compliance issues with national supervisors.
What does this regulation establish?
Directive (EU) 2024/927 amended two fundamental pillars of fund regulation in Europe: the AIFMD (Directive 2011/61/EU), which regulates alternative investment funds, and UCITS (Directive 2009/65/EC), which regulates harmonized collective investment funds. The five blocks of changes introduced by the original directive are:
| Regulated area | What Directive 2024/927 changed |
|---|---|
| Delegation of functions | New conditions and limits for managers to delegate management functions to third parties, within and outside the EU |
| Liquidity risk management | Strengthened obligations for funds to have liquidity risk management tools and procedures |
| Supervisory reporting statements | New periodic reporting obligations to national and European supervisors |
| Depositary and custody services | Update of conditions for the provision of depositary and custody services for fund assets |
| Loan granting by alternative funds | Regulated possibility for alternative investment funds (AIF) to grant loans directly |
The corrigendum published on 22 July 2026 corrects formal inaccuracies in the text of the original directive. It does not introduce new obligations or modify the transposition deadlines already established for Member States in 2024. However, the corrected text becomes the official reference version, replacing the original text published in the EU Official Journal on 26 March 2024.
Economic and operational impact
Although a corrigendum of a technical nature does not generate direct new costs, its operational impact is real for fund managers:
- Review of internal documentation: Any policy, procedure or manual that literally cites the text of Directive 2024/927 must be reviewed to check whether the corrections affect the referenced paragraphs.
- Compliance risk: Working with the uncorrected original text may generate interpretive discrepancies with the supervisor, especially in the areas of delegation and reporting, where the literal wording of the text matters.
- National transposition: Member States that are still completing the transposition of Directive 2024/927 must do so based on the corrected text, not the original.
- Loan granting by AIF: Managers structuring direct lending vehicles under the new regulation must verify that their legal analyses are based on the corrected text.
Who does it affect?
- Alternative investment fund managers (AIFM) authorized in any EU Member State under AIFMD (Directive 2011/61/EU)
- UCITS fund managers authorized under Directive 2009/65/EC
- Depositaries and custody entities providing services to AIF or UCITS funds in the EU
- Legal and compliance advisors working with asset managers in the EU
- National competent authorities in the process of transposing Directive 2024/927
- Alternative funds that operate or plan to operate direct lending strategies (direct loan granting)
Practical example
A Spanish alternative investment fund manager (AIFM) has been adapting its internal liquidity risk management procedures during 2024 and 2025, based on the text of Directive 2024/927 published on 26 March 2024. With the publication of the corrigendum on 22 July 2026, the compliance department must:
- Download the corrected text from EUR-Lex and compare it with the original text.
- Identify whether any of the formal corrections affect the articles regulating liquidity risk management or delegation of functions, which are the areas where the manager has made operational changes.
- Update internal manuals and documented policies to cite the corrected text as the reference source.
- Communicate the change to the fund's depositary, which must also work with the corrected official text regarding its custody obligations.
This process, although it does not imply substantive changes in the fund's strategy, requires legal review time and documentary updates that must be planned.
What should companies do now?
- Download the corrected text: Obtain the corrected version of Directive (EU) 2024/927 from the EU Official Journal on EUR-Lex and replace any reference to the original text of 26 March 2024.
- Review internal documentation: Identify all internal documents (policies, procedures, compliance manuals) that literally cite articles of Directive 2024/927 and verify whether the corrections affect them.
- Inform the legal and compliance team: Ensure that those responsible for regulatory compliance and external advisors work with the corrected official text, not the original.
- Verify applicable national transposition: Check the transposition status of Directive 2024/927 in the Member State where the manager operates, taking into account that transposition must be based on the corrected text.
- Review direct lending structures: Managers developing or already operating loan granting strategies by AIF must confirm with their legal advisor that the regulatory analysis is based on the corrected text.
- Update records with the supervisor: If any communication or record with the national competent authority makes express reference to the text of the directive, consider whether an update is appropriate.
Frequently asked questions
What exactly does the corrigendum to Directive (EU) 2024/927 correct?
The corrigendum corrects formal inaccuracies in the text of Directive (EU) 2024/927, originally published on 26 March 2024. It does not modify the substantive regulatory content or introduce new obligations: the changes are technical in nature and affect the formal wording of the official text. The five areas regulated by the original directive (delegation, liquidity, reporting, depositary and loans by AIF) do not change in their substantive content.
When should Member States have transposed Directive 2024/927?
The transposition deadlines for Directive (EU) 2024/927 were established in 2024, in accordance with the original directive text itself. The corrigendum published on 22 July 2026 does not modify those deadlines, but Member States that are still completing transposition must do so based on the corrected text, not the original.
Can alternative funds (AIF) grant loans directly after this directive?
Yes. Directive (EU) 2024/927 introduced the regulated possibility for alternative investment funds (AIF) to grant loans directly, one of the five major innovations of the regulation. The corrigendum of July 2026 does not alter this authorization, but managers structuring direct lending vehicles must ensure that their regulatory analysis is based on the corrected text and on the national transposition in force in their Member State.
Does this corrigendum affect UCITS funds or only alternative funds?
It affects both. Directive (EU) 2024/927 amended both AIFMD (Directive 2011/61/EU), which regulates alternative investment funds, and UCITS (Directive 2009/65/EC), which regulates harmonized collective investment funds. Therefore, the corrigendum is relevant for both AIF managers and UCITS managers.
What happens if my manager continues to use the original directive text instead of the corrected one?
Working with the uncorrected original text may generate interpretive discrepancies with the national supervisor, especially in areas where the literal wording of the text is determinative, such as delegation of functions or reporting obligations. Although the corrigendum does not introduce specific sanctions, the regulatory compliance risk increases if internal documentation and procedures are not based on the current official version.
Official source
Consult complete regulation in official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690614