Login to access your exclusive member-only content and account information.


Not a member? Join us

  • Operate to the highest level of professional standards
  • Access authoritative industry research and data
  • Navigate the complex EU regulatory environment
  • Network and engage with industry leaders
  • Home /
  • News & opinion /
  • Opinion /
  • The devil lies in… the implementation. Cross-border distribution of funds is still not straightforward.
News & opinion

The devil lies in… the implementation. Cross-border distribution of funds is still not straightforward.

01 Oct 2021

The Cross-Border Distribution of Investment Funds (CBDF) legislation became applicable across the EU in August 2021 and we owe you our apologies for not celebrating it with the requisite fireworks and champagne. Why? Our preoccupation with its implementation.

The legislation was originally born from long-standing concerns by the European Commission about how the differing marketing requirements, regulatory fees, and notification requirements between Member States could represent a significant barrier to efficient cross-border fund distribution and, as such, to the well-functioning of the capital markets we share a keen interest in.

Back in 2018, EU investment funds representing 70% of the total AuM were registered to be marketed exclusively in their own domestic market, and a paltry 3% of EU AIFs were registered to be marketed in more than three Member States.

So, there were reasons aplenty for addressing cross-border distribution of funds.

But alas (and here comes the reason for us not toasting and firing up just yet), while the CBDF package was initially developed to reduce barriers for investment managers marketing funds across the EU and to harmonise approaches across Member States, over the last few months it has become clear that Member States have not always (or have rarely) been consistent in how they interpret and implement the rules.

As a result, fund managers and investors are faced with a patchwork of national laws, leading to uncertainty and grey areas, in particular in those countries where implementation is delayed and/or further guidance is expected from the national competent authorities.

For that reason, we have developed a new Guide on the national implementation of the CBDF.  Prepared in cooperation with the Invest Europe Legal and Regulatory Committee, this Guide aims to provide a pan-European overview of how the CBDF has been transposed into national law across the EU.

The Guide looks at the rules from the perspective of both EU and non-EU fund managers, as well as smaller fund managers below the AIFMD threshold.

We trust that this Guide will help members navigate the myriad of national rules and serve as a tool to manage the impact this will have on their day-to-day operations and marketing activities.


Discover our new guide

Want to discuss?

We are always keen to hear from you.


What can I do to manage cookies stored on my computer or phone?

You can accept or refuse cookies. Accepting cookies is usually the best way to make sure you get the best from a website.

Most PCs automatically accept them but you can change your browser settings to restrict, block or delete cookies if you want. Each browser is different, so check the 'Help' menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences. Many browsers have universal privacy settings for you to choose from.

Help on how to set and customise your cookie settings for your browser

How to manage cookies in Internet Explorer

Cookie settings in most versions of Internet Explorer can be found by clicking the tools option and then the privacy tab.

How to manage cookies in Firefox

Cookie settings in Firefox are managed in the Options window's Privacy panel. See Options window - Privacy Panel for information on these settings.

How to manage cookies in Chrome

Click on the spanner icon on the toolbar, select settings, click the under the bonnet tab, click on content settings in the privacy section.

How to manage cookies in Opera 

You can manage cookies in Opera if you Click on settings, then Preferences, then Advanced and finally Cookies

How to manage cookies in Safari

Choose Safari, then preferences and then click security. You should then be able to specify if and when Safari should accept cookies.

To manage cookies on your mobile phone please consult your manual or handbook.

Get more help about how cookies work with specific browsers.

What happens if I don't accept cookies?

If you decline cookies, some aspects of Invest Europe site may not work on your computer or mobile phone and you may not be able to access areas you want on the website. For this reason we recommend that you accept cookies.

What happens if I delete my cookies?

If you delete all your cookies you will have to update your preferences with us again and some aspects of our site may not work.

What happens if I change computers or mobile?

If you use a different device, computer profile or browser you will have to tell us your preferences again.

If you'd like to learn more about cookies in general and how to manage them, visit

We can't be responsible for the content of external websites.

Opt-out of cookies


Join today

This is for members only. To view in full login or join Invest Europe today.