According to Article 110 of Regulation 231/2013, Alternative Investment Company Managers (ZASI) are required to submit periodic reports to the Polish Financial Supervision Authority (KNF). These reports are submitted annually — the report for the current year must be filed by January 31 of the following year.
The report, along with analytical data, must be submitted in XML format via the Electronic Information Submission System (ESPI), operated by KNF.
Required Report Contents
In the report submitted to KNF, the ZASI must include the following information:
- The main instruments traded, including a breakdown of financial instruments and other assets, investment strategies of the ASI, and the degree of investment concentration by geography and sector
- Markets in which the manager is active or conducts transactions; portfolio diversification details, including — but not limited to — key exposures and concentrations
Important: The analytical data must cover the activities of the ZASI as well as each ASI managed by the ZASI, regardless of whether any investment or operational activity is currently being conducted.
XML Reporting Structure
Reporting is carried out using XML files, including:
- A DATMAN file containing information about the ASI manager
- Separate DATAIF files for each ASI under management
This applies equally to internally managed ASIs, which must submit a DATMAN file with manager data and a DATAIF file with information about themselves as ASIs.
The XML reports are submitted to KNF by uploading the files to the ESPI system and completing the ESPI report with relevant attachments. All submitted files are validated through the IT system of the Office of the Polish Financial Supervision Authority (UKNF), which handles periodic reporting for ASI managers.
