Arkk Solutions are working with the GFSC to support AIFMD filers in Gibraltar
Last week we hosted a webinar regarding Gibraltar’s XML filing requirements. As of 31st January 2017, the GFSC will only accept AIFMD returns submitted in XML format. You will no longer be able to e-mail an Excel template to the regulator, and will instead need to e-mail* an XML file of your converted templates.
All submissions must comply with the current schema defined by ESMA, and should follow the ESMA AIFMD reporting IT technical guidance. As with all other jurisdictions, these checks and validations are a standard feature built into the templates for Arkk Solutions clients.
Common errors and how to avoid them
Arkk have been working with the Gibraltar regulator for the past year to fully support these requirements. To avoid resubmission, the GFSC have outlined the following common filing errors from previous reporting periods:
1. Submission document omissions
You must remember to include the file’s time and date of creation prior to XML conversion
2. Not completing all the mandatory questions
Depending on the AIF/AIFM content type there can be up to 80 mandatory questions. This number can grow, as depending on the data entered conditional fields can become mandatory.
3. Entering data with too many decimal places
A maximum of 2 or 4 decimal places are permitted for certain questions
To prepare for the filing deadline, the Arkk team recommend the following timeline:
1. Late September – Test Filing
The GFSA strongly recommend that you perform a test filing this month to iron out any issues prior to the first mandatory XML filing
2. Early January 2017 – Dry run
You should also perform a dry run prior to the filing deadline
3. 31st January 2017 – Live filing
You must have a solution for converting your Annex IV templates into XML if you are reporting from or into Gibraltar
*The GFSA may ask for a different approach in the future, but are currently requesting Q4 submissions via e-mail. We will update this page if the submission process changes.