Sweden Amends AIFM Rules on Investment Advice, Effective October 1, 2026

Key Takeaways

• Finansinspektionen (FI) has amended Chapter 10, Section 3 of FFFS 2013:10, which sets conduct and organizational requirements for AIFMs that advise clients on units or shares in alternative investment funds.
• The amendment takes effect October 1, 2026, and updates the cross-references to MiFID II Delegated Regulation articles and to FFFS 2017:2 on securities transactions.
• Affected AIFMs should confirm that their advisory activities comply with the revised provisions before the effective date.

Deep Dive

Finansinspektionen (FI) has amended Chapter 10, Section 3 of FFFS 2013:10, which sets conduct and organizational requirements for AIFMs that advise clients on units or shares in alternative investment funds. The amendment takes effect October 1, 2026, and updates the cross-references to MiFID II Delegated Regulation articles and to FFFS 2017:2 on securities transactions. Affected AIFMs should confirm that their advisory activities comply with the revised provisions before the effective date.

The AIFM must also apply Chapter 4 and Chapter 7, Sections 1–5, 8–11 and 13–23 of FFFS 2017:2 on securities transactions. Under the application of Chapter 7, Section 10, the trustee does not need to meet the requirements of Chapter 7, Sections 12 and 24. Because the text shows the revised wording rather than a redline, teams should compare it with the prior version of Chapter 10, Section 3 to identify which cross-references were added, removed or changed. This gap analysis is the key first step in determining the real impact.

The regulations enter into force on October 1, 2026, about two weeks after the decision date of September 15, 2026. This leaves very little time for implementation. Firms already applying MiFID-style advisory standards may need only limited adjustments. Firms with less developed advisory frameworks may face more significant changes to policies, procedures, client documentation and recordkeeping.

Recommended actions:
- Confirm whether the firm provides in-scope advisory services.
- Map current policies and controls to the cited MiFID II Delegated Regulation articles and FFFS 2017:2 provisions.
- Update procedures, training and client disclosures where gaps exist.
- Document the compliance assessment and brief senior management and the board.
- Escalate any gaps that cannot be closed by October 1, 2026, and consider early dialogue with FI.

The risk impact is moderate for in-scope firms and negligible for AIFMs that do not give advice. The main exposures are conduct and investor protection failures, supervisory findings and sanctions for noncompliance, and operational strain from a short implementation window. Cross-reference changes can be easy to overlook, so legal and compliance should verify them directly against the official FFFS 2026:29 text.

Source: Finansinspektionen