Fulfilling the obligation to obtain entry in the register of ASI managers (ZASI) does not relieve ZASI of its remaining duties toward the Polish Financial Supervision Authority (KNF). Both ZASI and ASI are required to fulfill reporting obligations to KNF, which enable the Authority to exercise its supervisory powers. Additionally, ASI must maintain financial reporting in accordance with specific requirements introduced by the Accounting Act.

According to Article 222c(1) of the Act on Investment Funds and Management of Investment Funds, ASI managers are required to prepare and submit to the Commission, in accordance with Article 110 of Regulation 231/2013, periodic reports concerning:

  • (i) investment activity conducted on behalf of managed alternative investment companies
  • (ii) liquidity and risk management of managed alternative investment companies — for each ASI
  • (iii) use of financial leverage by AIFs in managed ASIs that apply such leverage — for each ASI

These reporting obligations must be fulfilled in line with Article 110 of Commission Delegated Regulation (EU) No 231/2013 of December 19, 2012, supplementing Directive 2011/61/EU of the European Parliament and Council with respect to exemptions, general operating conditions, depositaries, leverage, transparency, and supervision. The Regulation introduces a closed catalogue of information that must be included in the reports.

Under the Regulation, the primary method of fulfilling reporting obligations is the submission of ASI investment activity reports to KNF using the reporting template provided in Annex IV of the EU Regulation — once per year, within one month after the end of the reporting period, i.e., by the end of January.

Files are submitted via the ESPI system. Unfortunately, validation often reveals errors due to inaccuracies in file preparation according to KNF requirements. Therefore, meticulous attention to detail — down to every comma and correctly placed period — is essential.

In summary, the scope of reporting obligations for ASI and ZASI operating under registry entry is quite broad and requires specialized knowledge, which may pose significant challenges. Despite statutory simplifications for such entities, reporting remains a critical aspect of their operations and must be continuously observed.