In May 2018, ESMA added a question on the disclosure of remuneration of delegates in its Q&A on the application of the UCITS Directive. In its answer, ESMA takes the same position as the one taken in the case of delegation by an AIFM (see our Newsletter December 2017). ESMA clarifies that the remuneration-related disclosure requirements under Article 69(3) (a) of the UCITS Directive also apply to the staff of the delegate of an AIFM to whom portfolio management or risk management activities have been delegated. In line with the approach followed under the UCITS Remuneration Guidelines, ESMA provides for two different ways of complying with this requirement.
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