Tilsynsrapport - REQ AS

The review formed part of an ESMA common supervisory action, signalling continued European-level scrutiny of governance and internal control arrangements for asset managers. For compliance teams, the key message is to evidence that control functions are operationally independent, adequately resourced and have clear reporting lines to senior management and boards. Internal audit should be risk-based, cover all material activities including delegated and outsourced functions where relevant, and follow a documented plan with appropriate escalation of findings.

Firms should benchmark current frameworks against ESMA expectations, review terms of reference, staffing and access rights, and ensure board minutes and management information demonstrate active oversight. Where gaps are identified, remediation should be tracked with clear ownership and timelines. The excerpt does not set a specific new deadline, but supervisory follow-up is likely.

Smaller AIF managers may face proportionately greater resourcing challenges; larger groups should verify group-level audit coverage and local governance. Action now: conduct a gap assessment, refresh internal audit plans, document independence and resourcing, and prepare for possible information requests. This is a moderate but clear governance signal rather than a new rulebook.