In accordance with the KNF guidelines reflecting those of the European supervisory authority (ESMA), the report for a given year must be submitted by the end of January of the following year (Art. 110 of Regulation 231/2013) in the form of structured XML files, which include information on both the AIFM and the AIF. The absence of operational activity does not exempt from this obligation, as the KNF also requires the submission of files showing a zero portfolio.
The obligation to submit reporting files for 2025 applies to entities registered as AIFMs by 30 September 2025. Entities registered in the fourth quarter of 2025 are not required to submit XML files for 2025.
The scope of required disclosures, even in the simplified reporting format, is significant and includes the data specified in the regulation “on supplementing the disclosure obligations of managers of alternative investment funds.” However, it seems that despite the need to present data in a codified form with the required level of detail, preparing the data itself is not the biggest challenge. One must bear in mind that AIF portfolios are currently in the build-up phase, and the diversity of investment activities remains limited. In our view, the greatest difficulty lies in preparing files in the format required by the KNF (https://www.knf.gov.pl/dla_rynku/espi). This is particularly problematic as the structure is not supported by standard accounting and reporting software.
We have the necessary expertise and experience in the KNF reporting process, ensuring efficient and competent execution of reporting obligations. For the past six years, we have been actively involved in regulatory reporting to the KNF and, to a large extent, have had the opportunity to co-develop the reporting standard with the national regulator. This is why we want to share our knowledge with the market. Below is a technical presentation that may be helpful in preparing batch files for the KNF independently.
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Managers of Alternative Investment Companies (AIFMs), in accordance with Article 110 of Regulation 231/2013, are required to regularly submit reports to the Polish Financial Supervision Authority (KNF). This obligation covers the submission of reports in XML format via the Electronic Information Transmission System (ESPI).
In the reports, the AIFM provides, among others:
Managing the reporting process to the KNF is a key challenge for AIFMs. Fundequate and Genprox are leaders in reporting support, assisting Alternative Investment Companies in meeting regulatory requirements.
We are an accounting and advisory firm specializing in the accounting of AIFs. We possess broad professional expertise and hold certifications such as Investment Advisor, ACCA, and Tax Advisor. This enables the VC funds we serve to receive, in one place, a comprehensive service unavailable from any other accounting firm or law office. We specialize in servicing VC funds and have a deep understanding of their reporting needs. As a result, we are able to provide full accounting, tax, and reporting support for any type of VC/PE fund in Poland as well as for alternative funds in Luxembourg.
The preparation of the XML report of an AIF for submission to the KNF requires the collection of financial and operational data, compliance with KNF requirements, and the correct generation of the XML file. The simplest solution is to use the services of Genprox or the Fundequate platform, which provide comprehensive support – from data analysis to the automatic generation of an XML file fully compliant with KNF requirements.
The annual AIF report must include details of the investment portfolio, financial results, risk management, and other required data. With the Fundequate platform, you can easily complete all the necessary sections, while GENPROX provides additional verification to ensure the report complies with regulations.
The deadline for submitting the annual report for AIF managers operating on the basis of registration with the KNF falls at the end of January of the year following the reporting period, i.e. 31 January 2026 for the year 2025. To avoid delays and KNF sanctions, use the services of Genprox – our experts will ensure the timely preparation and submission of the report to the KNF via the Fundequate platform.
Raport XML ASI to dokument, który zarządzający alternatywnymi spółkami inwestycyjnymi muszą złożyć do KNF. Powinien być przygotowany w zgodzie z wymaganiami technicznymi regulatora. Platforma Fundequate umożliwia szybkie generowanie poprawnych raportów, a eksperci Genprox oferują pełne wsparcie na każdym etapie procesu.
The DATMAN and DATAIF reports, submitted by Alternative Investment Fund Managers (AIFMs) to the Polish Financial Supervision Authority (KNF), contain detailed data on the investment activities of all managed AIFs. They constitute a mandatory element of regulatory oversight, ensuring transparency of AIF operations in relation to the KNF. Upon receipt, the KNF forwards these reports to the European Securities and Markets Authority (ESMA), supporting the harmonisation of supervision at the EU level.
The KNF requires that the report comply with the specified XML schema and include accurate data on the activities of the AIF. By using the Fundequate platform and the support of Genprox, you can be confident that your report meets all requirements and is ready for submission. In reporting to the KNF for AIFs, we have 6 years of experience, with 70% of the assets under management of Polish AIFs reported by us.
AIF managers who were entered into the AIFM register maintained by the KNF before 30 September of a given year are required to submit a report to the KNF for the entire preceding calendar year no later than 31 January of the following year. If the entry into the AIFM register took place in the fourth quarter of the year, the reporting obligation for that period does not apply. The same rules apply to subsequent AIFs managed by the AIFM – reports cover only those AIFs that were registered with the KNF by the end of the third quarter.
The most common errors are non-compliance with XML requirements or incomplete data. To avoid these, use the Fundequate platform, which automatically validates the report. Genprox experts will also help you verify the data and ensure that the report meets KNF standards.
Yes, you can entrust the preparation of the report to specialists. Genprox offers comprehensive reporting services, and with the Fundequate platform the process is fast and fully compliant with KNF regulations. This solution saves time and helps avoid errors.
Failure to submit the report, or submitting it late, may result in financial penalties and, in extreme cases, even the removal of the AIF manager from the KNF register.
Technical verification can be carried out using KNF tools or automatically on the Fundequate platform, which immediately identifies potential errors. In addition, Genprox provides a detailed review of the report and full support with its corrections.
Genprox is an expert in preparing AIF reports for the KNF, offering support at every stage of the process. Through integration with the Fundequate platform, you can be assured that your report will be prepared in compliance with requirements and submitted on time. This solution minimises the risk of errors and saves you valuable time.