Applying for a permission

In-scope Alternative Investment Fund Manager (AIFM)



The purpose of this page is to explain the application process for an In-scope Alternative Investment Fund Managers (In-scope AIFM).

This section sets out:

  • What an In-scope AIFM is and what this regulated activity would allow you to do
  • Application Process
  • Capital Requirements 
  • Additional Information

What is an In-scope Alternative Investment Fund Manager and what would this regulated activity allow you to do?

The Alternative Investment Fund Managers Directive 2011/61/EU (AIFMD) requirements are set out in the Financial Services (Alternative Investment Fund Managers) Regulations 2020. 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 fall within the scope and definition of AIFMs.

An AIFM regulated activity will allow the applicant to manage one or more AIFs.

The permission issued will specify the scope of services and instruments that the firm can carry on business in, from the list below.

  1. Investment management - portfolio management.
  2. Investment management - risk management.
  3. Administration: Legal and fund management accounting services.
  4. Administration: Customer inquiries.
  5. Administration: Valuation and pricing, including tax returns.
  6. Administration: Regulatory compliance monitoring.
  7. Administration: Maintenance of unit-/shareholder register.
  8. Administration: Distribution of income.
  9. Administration: Unit/shares issues and redemptions.
  10. Administration: Contract settlements, including certificate dispatch.
  11. Administration: Record keeping.
  12. Marketing.
  13. Activities related to the assets of AIFs.
  14. Management of Portfolios of Investments.
  15. Non-core: Provision of investment advice.
  16. Non-core: Safe-keeping and administration in relation to shares or units of collective investment undertakings.
  17. Non-core: Reception and transmission of orders in relation to financial instruments.

In-scope AIFMs carrying out investment services, authorised in Gibraltar, are also required to be members of the Investor Compensation Scheme. Further information is available on the Gibraltar Investor Compensation Scheme website at 


Application process

Applicants should submit an application form and additional documentation with all relevant documents. We will not consider an application complete if there are any outstanding documents.

The application pack must consist of:

  • Application Fee;
  • Application Form;
  • Financial Projections for the next 3 years;
    • Stress Test on Financial Projections;
    • Profit and Loss account;
    • Balance Sheet;
  • Regulated Individual Form (for each Regulated Individual);
  • Non-Executive Director Form (for each non-executive director);
  • Controller Form (for each Controller);
  • Business Plan;
  • Details of the AIFs it intends to manage, including: 
    • The AIFs’ investment strategies, including the types of underlying funds, their policy on the use of leverage and their risk profiles;
    • The rules or instruments of incorporation of each AIF; and
    • Arrangements made for the appointment of the depositary for each AIF.
  • AIFMD Reporting Template;
  • Risk methodology and Framework;
  • Supporting Policies and Procedures;
  • Details of Source of Wealth/Source of Funds (including final ownership structure, details of capital within the group, how the funding will be provided, access to further funds and 3-year financial statements for companies providing the funding. If an individual will provide more than 10% of the funding, we will require an independently verified statement of wealth);
  • Business Continuity Plan; and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application.

Please request cloud access from the Authorisation team in order to submit the application pack via E-mail at with the following information in the subject field: ‘Name of Regulated Firm/Applicant – Application’. Paper copies are not required unless indicated by the Authorisation team.

Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.  

Additional Services

Regulated Firms that are already authorised by the GFSC may apply to extend their permission to provide additional financial or professional services. If you are seeking authorisation for additional services, please contact the Authorisation team in order for us to determine what documents are required for submission.

The below sets out an overview of the expected information requested:

  • Application Fee (if applicable);
  • Revised Business Plan;
  • Financial Projections for the next 3 years, clearly identifying the impact of the additional business:
  • Profit and Loss account
  • Balance Sheet
  • Stress Test on Financial Projections
  • Regulated Individual Form (for any new individual carrying out a Regulated Individual function);
  • Controller Form (for any new Controllers within the structure); and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application.

The Regulated firm should consider the following:

  • What new services/permissions it requires;
  • The type of new business/activity;
  • Where the business will be sourced;
  • Resources to deal with the additional business;
  • The impact of the additional business on its capital requirements; and
  • What changes are being effected to its systems and controls.

Capital Requirements

An AIFM’s minimum initial and ongoing capital requirements are the higher of:

  • €125,000 (or where a self-managed AIFM, €300,000); or
  • The own funds calculation as per AIFMD.

Additional Information

The business plan should comprehensively set out:

  • The AIFM’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, including the AIFM’s marketing strategy;
  • The arrangements that will be put in place to safeguard customer monies and/or assets;
  • How the AIFM’s 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 by the AIFM to its clients; and
  • If the applicant forms part of a larger group, details of the activities of the group and a description of their structure.

The GFSC will also be seeking evidence that the firm has considered and documented the risk, compliance and operational issues associated with its proposed activities. We will also seek evidence that the firm has implemented adequate procedures.

Firms should consider the 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.