Small Scheme Managers

This section sets out:

  • What would this licence allow you to do?
  • Capital Requirements
  • What do you need to submit?
  • Alternative Investment Fund Managers (AIFMs)

The Alternative Investment Fund Managers Directive 2011/61/EU (AIFMD) was transposed in Gibraltar legislation via the Financial Services (Alternative Investment Fund Managers) Regulations 2013. AIFMD does not directly regulate the operations of Alternative Investment Funds (AIFs) but instead regulates the managers of the AIFs, i.e. the AIFMs. It is therefore prudent to determine who the AIFM is for the purposes of the AIFMD as some AIFs may themselves be considered AIFMs.

What would this licence allow you to do?

This licence allows an AIFM to manage portfolios of AIFs, whose assets under management do not exceed the de-minimus threshold and which does not elect to opt-in to the full authorisation process under the AIFMD. 

Capital Requirements

Small Scheme Managers are required, on an ongoing basis, to self-assess the level of financial resources required to be able to meet its liabilities and ensure an orderly wind-down, subject to a minimum of £15,000.

What do you need to submit?

An application pack is required to be submitted together with all the relevant documents, it is not possible to consider an application if there are any outstanding documents.

The application pack must consist of:

  • Application Form
  • Business Plan
  • Financial projections for the next 3 years
  • Profit and loss account
  • Balance sheet
  • Returns (these need to be on a quarterly basis for the first year and then annually for the following 2 years)
  • Authorised AIFM (B2) Reporting Template
  • Individual Questionnaires (for each individual holding a notifiable position)
  • Body Corporate Questionnaires (for each entity holding a notifiable position)
  • Any other document that the GFSC considers to be neccesary as part of the application
  • Mapping assessment of how the application meets the relevant legislative threshold requirements (i.e. statutory/regulatory criteria for licensing under relevant Act/s)

An AIFM applying for authorisation shall provide the following information relating to the AIFM to the GFSC:

  • Information on the persons conducting the business
  • AIFM's shareholders
  • Organisational structure
  • Information on the AIFs it intends to manage:
  • The investment strategies including the types of underlying funds, AIFM’s policy on the use of leverage and the risk profiles
  • The rules or instruments of incorporation of each AIF
  • Arrangements made for the appointment of the depositary for each AIF

Business Plan

The business plan should clearly and comprehensively set out:

  • The firm’s proposed activity and how it will be conducted
  • The resources that will be made available and the systems that the applicant intends to employ
  • How clients will be attracted
  • What arrangements will be put in place to safeguard client monies and/or assets
  • How records will be maintained
  • How, and by whom, any significant decisions will be made
  • How the firm complies with the Anti-Money Laundering requirements
  • The level and nature of fees to be charged to the firm’s clients

If the applicant forms part of a larger group, details should also be provided of the activities of the group and a description of their structure.

The GFSC will also be seeking evidence that the firm has considered the risk, compliance and operational issues associated with the proposed activities, as well as evidence that these have been documented and implemented.

Firms should consider the relevant AIFMD requirements in their entirety prior to submitting an application. The GFSC Information Pages may also be of assistance as they set out the requirements specific to the relevant area.

Application Forms

Should you get an error when opening any of the forms, please check the FAQ tab for guidance on how to override this.


Application Form

Documents referred to in the application form must be clearly referenced to help us process the application swiftly.


RGP Vetting Form

Please note that an 'Individual Questionnaire' or a 'Notifiable Document' MUST be accompanied by a Royal Gibraltar Police Vetting Application Form in accordance with Section 30C of the Proceeds of Crime Act 2015.  The form must be submitted to the Gibraltar Financial Services Commission, who will liaise with the RGP in order to make the relevant enquiries.

For any applicant that is not a Gibraltarian, or has not lived in Gibraltar for the last 10 years, in addition to the RGP vetting form, he/she must also provide the GFSC with a report of their criminal record from the relevant authority in the jurisdiction/s in which they have been ordinarily resident for the last 10 years and/or from any other jurisdiction where the applicant has spent a considerable amount of years resident in the past.  If the report is not in English, this must be accompanied by a translation from a certified Translator.


Notes for completion of the Royal Gibraltar Police Vetting Application Form:

1.     The RGP Vetting Form must be completed by the applicant in full. Should any section be incomplete, this cannot be accepted. 

Note that the section in the form that states ‘To be completed by agency or organisation requiring vet’ should be left blank as this section is to be completed by the GFSC only. 

2.     All RGP Vetting Forms MUST be submitted together with the applicable Individual Questionnaire or Notifiable Document to which it relates. 

Please note that all applications/fit and proper assessments will be kept on hold and not be processed until the original RGP Vetting Form and fee is submitted together with the applicable Individual Questionnaire or Notifiable Document. The same will apply to any incorrect forms submitted.

If an Applicant has submitted an RGP Vetting Form within the last 12 months, please contact the Authorisations Team at to confirm whether the individual is required to re-submit.

Should exceptional circumstances apply, please contact 

3.     The RGP and Individual Questionnaire or Notifiable Document cannot be accepted without any of the following:

a)    Payment of the £10 applicable fee by bank transfer only; and

In order to obtain the relevant bank details, please liaise with the member of staff at the GFSC who is processing the application and they will provide you with the required information. Should you be unsure of the contact details, then please refer your query to 

b)    APPLICATION Reference number. 

Please quote the following payment reference for any bank transfer:

For an individual: “RGPNAMEOFAPPLICANT” 

For payments to settle for more than one applicant: i.e. If the firm is submitting an application for five individuals, the reference should be as follows: “RGPNAMEOFFIRMX5”

For any further queries, please contact and a member of staff will be happy to assist. 

 Individual Questionnaire
 Body Corporate Questionnaire

Body Corporate Questionnaire Warranty

A warranty signature page is required to be submitted with all applications. Please use the reference number quoted on the form.


Individual Questionnaire Directors Declaration

Directors declaration form is required to be signed and submitted with the individual questionnaires. Please use the reference number quoted on the form.


Individual Questionnaire Warranty

A warranty signature page is required to be submitted with all applications. Please use the reference number quoted on the form.

 AIFM Reporting Template - Authorised AIFM

A1 - This form should be completed and submitted to the FSC by authorised AIFMs and authorised self-managed AIFs.

** All forms are accepted electronically so long as they are submitted from a valid email address pertaining to the firm **


Service Level Standards

The current service level standards are:

  • To provide initial feedback to an application within 5 weeks of a complete application being received.
  • Once all of the information has been received from an applicant and the application is therefore considered to be complete, we aim to provide an in principle decision within 4 weeks.

Please be advised that the above service level standards refer to the period of time in which the GFSC holds applications for consideration. Where we require further information or documents from an applicant the service level standards will be suspended until we receive the requested information. The period of time an application is pending because of factors outside the control of the GFSC will not be accounted for under the service level standards.

Please note that should we be unlikely to meet our SLS’s, we will advise you as soon as possible.