The DORA Register of Information for fund managers

A manager of alternative investment funds (AIFM) or a UCITS management company fills in the same Register of Information as any other financial entity, and files it with the AFM the same way. Four things differ: light managers fall outside DORA, there are two entity types, the licensed activities in B_06.01 follow the AIFM or the UCITS Directive, and a manager in a group may be covered by the group's register. The route from workbook to AFM Portal is in the guide to filing with the AFM.

Does DORA apply to you

With a licence, yes; with only a registration, no. DORA lists managers of alternative investment funds and management companies in Article 2(1)(k) and (l). Managers as referred to in Article 3(2) of the AIFM Directive are excluded (DORA, Article 2(3)(a) (opens in a new tab)).

The AFM describes the Dutch AIFMD registration regime as the de minimis exemption of that Article 3(2); managers under it are called light managers (AFM, AIFMD Q&A (opens in a new tab)). If you are unsure about your own position, ask the AFM at [email protected].

The competent authority under DORA is, for an AIFM, the one under Article 44 of the AIFM Directive, and for a management company the one under Article 97 of the UCITS Directive (DORA, Article 46(i) and (j) (opens in a new tab)). If you must file with the AFM, a reporting obligation is waiting for you in the AFM Portal (AFM (opens in a new tab)).

Type of entity in B_01.01 and B_01.02

You choose one of two codes from the EBA's closed list (EBA (opens in a new tab)). The same field (0040) is in B_01.01 for the reporting entity and in B_01.02 for each entity in scope.

Code	Label in the drop-down	For whom
eba_CT:x307	managers of alternative investment funds	Manager of alternative investment funds
eba_CT:x639	Asset management companies	UCITS management company; the EBA's Annex 2 list describes this type as "management companies" under Article 2(1)(b) of Directive 2009/65/EC

If you hold both licences, choose one type for your LEI and ask the AFM which. The register still covers the contracts and ICT providers of all your activities (EBA FAQ Q10 (opens in a new tab)).

Licensed activities in B_06.01

In B_06.01 (field 0020) you give the licensed activity of each function. The EBA's Annex 2 list maps these codes to the two types (EBA (opens in a new tab)):

Code	Label (EBA)	AIFM	UCITS management company
eba_TA:x183	management of portfolios of investments (AIFMD)	Yes	–
eba_TA:x184	management of portfolios of investments (UCITSD)	–	Yes
eba_TA:x260	risk management	Yes	–
eba_TA:x261	legal and fund management accounting services	Yes	Yes
eba_TA:x262	customer inquiries	Yes	Yes
eba_TA:x263	valuation and pricing, including tax returns	Yes	Yes
eba_TA:x264	regulatory compliance monitoring	Yes	Yes
eba_TA:x265	maintenance of unit-/shareholder register	Yes	–
eba_TA:x267	maintenance of unit-holder register	–	Yes
eba_TA:x266	unit/shares issues and redemptions	Yes	–
eba_TA:x268	unit issues and redemptions	–	Yes
eba_TA:x269	contract settlements (including certificate dispatch)	Yes	Yes
eba_TA:x270	distribution of income	Yes	Yes
eba_TA:x271	record keeping	Yes	Yes
eba_TA:x272	Marketing	Yes	Yes
eba_TA:x273	services necessary to meet the fiduciary duties of the AIFM	Yes	–
eba_TA:x133	Reception and transmission of orders	Yes	–
eba_TA:x137	Investment advice	Yes	–
eba_TA:x274	investment advice concerning one or more of the instruments listed in Annex I, Section C to Directive 2004/39/EC	–	Yes
eba_TA:x176	safe-keeping and administration in relation to shares or units of collective investment undertakings	Yes	–
eba_TA:x177	non-core services (safekeeping and administration in relation to units of collective investment undertakings)	–	Yes

Watch the look-alike pairs: the unit-holder register and the issue and redemption of units each have one code for AIFMs and another for UCITS management companies. For supporting functions, every type uses eba_TA:x276, "Supporting function".

• One identifier per combination: if a function serves several activities, create a separate function identifier for each combination of LEI, function and activity (AFM Q&A (opens in a new tab)).
• Validity: the EBA published the list for the 2025 reporting, under data model 4.0. The AFM says the data model did not change for 2026 (AFM Q&A (opens in a new tab)).

Crypto services

A UCITS management company or an AIFM may, after notifying its supervisor at least 40 working days in advance, provide crypto-asset services equivalent to the portfolio management and non-core services it is authorised for (MiCA, Article 60(5) (opens in a new tab)). These are reception and transmission of orders, advice, and portfolio management for crypto-assets. Their codes are on the page for crypto-asset service providers.

Part of a group

If you fall within the prudential consolidation of a group from another sector, your register is part of that group's consolidated register and is not reported separately. The EBA's own example is a fund manager in an insurance group (EBA FAQ Q5 (opens in a new tab)). Outside it, you report yourself. The level at which you file with the AFM is in the filing guide.

Further reading

• Filing the Register of Information with the AFM
• Choosing a converter
• The template pages for B_01.01, B_01.02 and B_06.01