Central Bank publishes updated Minimum Capital Requirements Reporting Template for AIFMs and UCITS Management Companies

The Central Bank has released two updated Minimum Capital Requirements Reporting Templates for AIFMs and UCITS Management Companies.
The revised MCR incorporates changes to Article 17(6) of the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 and Regulation 10(5) of the European Union (Alternative Investment Fund Managers) Regulations 2013. These amendments ensure that own funds of a UCITS Management Company or AIFM must never be less than the amount specified in Article 11 of the IFR, known as the fixed overhead requirement.
Furthermore, the updated MCR outlines the additional capital requirement for UCITS Management Companies and AIFMs authorized to offer individual portfolio management services, as outlined in the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Undertakings for Collective Investment in Transferable Securities) (Amendment) Regulations 2023 (S.I. No. 565 of 2023) and Part B of Chapter 3, Alternative Investment Fund Manager Requirements, in the AIF Rulebook.
The updated MCR will not apply to UCITS Management Companies or AIFMs authorised on or before 27 November 2023 until 27 May 2024 but will apply on authorisation to UCITS Management Companies or AIFMs authorised from 27 November 2023.
Along the two templates, the Central Bank also updated its tow corresponding guidances:
The “Minimum Capital Requirement Report – Guidance Note for AIFMs and UCITS Management Companies (Applicable until May 27th 2024 for all firms holding UCITS Management Company authorisation and/or AIFM authorisation on or before November 27th 2023)“ outlines the reporting intervals, signatory requirements, and the initial capital requirement. The guidance includes sections on professional liability risks, minimum capital requirement, eligible assets, previous guarantees, professional indemnity insurance, compliance test, and qualifying subordinated capital. The document also details the Central Bank of Ireland Portal user guide for uploading the report. The user is guided through the process of loading the file, validation, and finalization, with instructions on handling rejections and resubmissions. The report emphasizes the need for accuracy and compliance with regulatory capital requirements, with a focus on financial soundness and risk management.
The “Minimum Capital Requirement Report – Guidance Note for AIFMs and UCITS Management Companies (Applicable from November 28th 2023 for Firms authorised from that date as either a UCITS Management Company and/or AIFM and from May 27th 2024 for all firms authorised as either a UCITS Management Company and/or AIFM)“ explains how to submit the Minimum Capital Requirement Report by AIFMs and UCITS Management Companies to the Central Bank of Ireland. The guidance covers various aspects of the capital requirement calculation, such as Initial Capital Requirement, Fixed Overheads Requirement, Professional Liability Risks, K-Factor Capital Requirement, Previous Guarantee, Professional Indemnity Insurance, Compliance Test, and Subordinated Loan Capital. The guidance note also provides a user guide for uploading the report template to the Central Bank Portal, following the naming convention and the validation process.