Due diligence guide · AIMA DDQ

AIMA DDQ Explained: A Practical Guide for Fund Managers

Understand the AIMA due diligence questionnaire, choose the right AIMA DDQ template, verify the 2025 edition and prepare evidence-backed responses.

Edition reference
Final 2025 investment-manager DDQ
Review scope
Public AIMA sources
Updated
Published by
AgentKYZ

What is an AIMA DDQ?

An AIMA DDQ is a due diligence questionnaire published by the Alternative Investment Management Association. Investors use its investment-manager questionnaires to assess a manager’s business, governance, investment approach, operations and fund arrangements. Separate AIMA questionnaires help managers assess service providers, directors and boards.

For a fund manager responding to an investor, the practical task is to select the right template, describe how the business actually operates and connect each material answer to evidence. A policy document can show what should happen. A dated review, approval or exception record helps show what happened.

AIMA describes the DDQ as an early step in due diligence. Investors use responses to identify follow-up questions and cross-check information from other sources. Submission does not mean that due diligence is complete or that an investor has approved the manager.

Authored by AgentKYZ. This independent guide reviews AIMA’s public edition notices, resource listings and access guidance as of 13 October 2026. Its edition reference is the final 2025 investment-manager DDQ. We have not reviewed every restricted template or reproduced AIMA’s questionnaire text. The preparation workflow below is AgentKYZ’s recommendation, not an AIMA-issued checklist.

What is AIMA?

AIMA stands for the Alternative Investment Management Association, the membership association for alternative investment managers. Its work covers hedge funds, private market funds and digital asset funds; the Alternative Credit Council (ACC) is its private credit affiliate. See AIMA’s own description of its role.

AIMA develops industry resources, including due diligence questionnaires and sound-practice guides. It is not a financial regulator. Membership, use of a DDQ and compliance with applicable law are different matters. A completed questionnaire creates neither an “AIMA compliance” status nor regulatory approval.

Choose the questionnaire family and modules

Start by identifying who is being assessed. A manager answering an allocator’s questions and a manager reviewing its administrator need different questionnaires.

  • Investment-manager DDQs: for investors assessing a manager and the relevant fund or account. The suite uses combinations of manager, strategy and product modules.
  • Private-credit manager DDQs: AIMA’s 2025 launch notice describes ACC-branded options involving corporate lending or private markets strategies. Confirm the appropriate combination for the mandate.
  • Service-provider DDQs: separate resources for assessing providers such as fund administrators and prime brokers. An administrator questionnaire is not a substitute for the manager’s response to its investor.
  • Specialist questionnaires: AIMA also lists resources covering topics such as cyber security, outsourcing and responsible investment. Check whether the selected manager template already covers a topic before requesting a separate document.

Use the official AIMA investment-manager DDQ decision tree to find a starting template. Its first distinction is the respondent’s role: investment manager, sub-adviser or platform provider. AIMA explains that its suggested sub-adviser starting documents omit a product module, while platform-provider starting documents omit a strategy module. The contractual role matters more than the firm’s preferred label.

Before downloading, agree the scope with the requesting investor:

  1. Name the responding legal entity and the funds or accounts covered.
  2. Confirm the structure, such as an open-end fund, closed-end fund or managed account.
  3. Identify the relevant strategy modules. Public listings include trading strategies, corporate lending, private markets, funds of funds, models and systematic trading, and digital assets.
  4. Confirm whether a full or short-form response is acceptable and whether supplementary questions are needed.
  5. Record the template ID, edition, selected modules and response date in your working file.

A short form reduces the initial response scope; it does not prevent an investor from asking for more information. Avoid building a universal questionnaire by combining every module. For the provider-side process, use our fund-administrator due-diligence guide.

AIMA DDQ editions verified for this guide

The edition checks below use AIMA’s public pages reviewed on 13 October 2026. Resource labels establish which edition is being referenced; they do not establish that we have inspected the contents of a restricted download.

  • Investment-manager suite: final 2025 edition. The 12 March 2025 announcement explicitly calls that release a soft launch. AIMA’s subsequent March-to-final transition page confirms a final 2025 edition and lists template and module blacklines dated 16 November 2025.
  • Private-credit manager suite: 2025 edition. The March announcement confirms the ACC suite was also updated for 2025. The final-edition transition page includes ACC-branded template blacklines. Check the selected ACC template’s own details before use.
  • Administrator questionnaire: separately labelled “2017, 2025”. The official administrator landing page uses the title “AIMA DDQ for Administrators (2017, 2025)”. Do not apply the investment-manager suite’s release history to this separate resource or infer its precise changes from that label.

This guide does not claim a new “AIMA DDQ 2026 edition”. The review date is not the questionnaire’s edition year. Other questionnaire families have their own version histories, so verify each selected resource through AIMA rather than assuming everything shares the manager suite’s date.

If you are migrating an older response, use AIMA’s 2019-to-2025 transition resources. If your working document came from March 2025, use the March-to-final blacklines as well. Some FAQs in the general DDQ library still discuss 2017 and 2019; use the dedicated edition pages to resolve version questions.

What changed in the AIMA DDQ 2025 update?

In its March 2025 announcement, AIMA describes refinements to AML questions, outsourcing and technology risks, service providers, performance presentations, strategy descriptions, counterparty risk, leverage, liquidity risk management and expense disclosures.

The same notice identifies a new Private Markets strategy module, integration of technology and fund-director questions, separation of trading questions from operations and risk management, and more flexibility in data responses and presentation. These are changes described at the soft launch, not our own comparison of every final question. Use AIMA’s final-edition blacklines to check the changes affecting your chosen modules.

For an existing response library, review the evidence as well as the wording. A previously approved answer may describe a former administrator, an obsolete policy or a process that has since changed. Carry forward the answer only after its owner confirms that it remains accurate for the stated entity and period.

Where to get an official AIMA DDQ template

Obtain the AIMA DDQ template through AIMA’s official DDQ library and the linked decision tree. The library states that AIMA members can download the questionnaires. AIMA also licenses use on selected third-party DDQ platforms, subject to its terms and membership verification.

If you are not a member but an investor has requested an AIMA due diligence questionnaire, confirm the permitted access and completion route with AIMA and the investor. Receiving a copy does not establish a general right to redistribute it, publish it on your website or upload it into another platform. Check the terms applicable to the actual template and proposed use.

AIMA’s platform FAQ says that loss of membership ends future template access through the platform, while previously distributed DDQs completed during membership may be retained. That specific permission should not be read as unrestricted reuse of the underlying template.

This page is an explanatory guide, not an official AIMA DDQ download. AgentKYZ does not reproduce the restricted questionnaires here or claim AIMA membership, partnership or endorsement. Our evidence-preparation recommendations are original operational guidance. Do not treat them as a replacement template.

Assign response ownership before drafting

Appoint one coordinator to manage the request, deadline and version history. Investor relations or the COO’s team may perform that role, but each answer needs an owner who can verify the underlying facts. The following is an illustrative allocation to adapt to your organisation:

  • Investor relations or the coordinator: manages scope, investor-specific questions, approved wording, attachments and distribution.
  • Investment and risk teams: validate strategy, portfolio construction, trading, counterparty, leverage and liquidity responses within their responsibilities.
  • Operations and finance: confirm fund structures, valuation processes, performance data, expenses and service-provider arrangements with the relevant specialists.
  • Compliance and the MLRO: review AML/KYC descriptions, escalation arrangements and compliance statements against the applicable framework and approved policy.
  • Technology and security owners: verify system access, technology risks, continuity arrangements and the evidence supporting those descriptions.
  • Administrators and other providers: supply facts and supporting records for the work they perform. The manager’s responsible owner checks those inputs against the agreed service scope.

Give each response an evidence reference, an as-of date and an approver. Reconcile differences between the DDQ, offering documents, policies, service agreements and actual practice before release. Where work is incomplete, describe the gap and current controls accurately; a planned control should not be presented as operational.

The manager’s authorised approvers should approve the final response. For AML/KYC work supported by AgentKYZ, the client’s MLRO retains approval and the regulated entity retains compliance responsibility.

If you need external support, our guide to investor DDQ completion compares outsourced writers, response software and AML/KYC evidence support, with questions to ask before appointing a provider.

Prepare supporting evidence for your answers

Ask “What evidence supports your answer?” before polishing it. Build an index that lets an authorised reviewer retrieve the right record without exposing the entire client or investor file.

For each material statement, record the control area, evidence needed, responsible person, last review, known gap and remediation status. Add the document location, version, period covered and approval where relevant. This is an AgentKYZ preparation approach, not an AIMA-prescribed evidence list.

Useful evidence depends on the selected questions and your operating model. It may include approved policies, governance records, service agreements, risk assessments, control-test results, valuation records and documented exceptions. For AML and KYC descriptions, check whether you can substantiate:

  • How investor risk ratings are assigned and reviewed.
  • How identity, beneficial ownership and control are verified.
  • How screening results are assessed, cleared or escalated, with a recorded rationale.
  • How source-of-funds and source-of-wealth evidence is assessed where required.
  • How periodic reviews, trigger events and unresolved exceptions are tracked.
  • How the manager oversees outsourced work and retrieves supporting records.

Illustrative example: a manager says that its administrator performs periodic investor reviews. The support could include the agreed review policy, the review population and due dates, a risk-based sample of completed files, overdue cases and escalation records. The service agreement alone does not show that the reviews took place. A sample also does not justify a claim that every file is complete.

An investor uses a manager DDQ to investigate the fund manager; the manager performs KYC to investigate the investor. Those processes are different, but evidence from the second can support statements made in the first. Our guide to preparing AML and KYC evidence for an AIMA DDQ develops that evidence workflow.

For the underlying controls, use our AIMA customer due diligence guide to organise the investor file and our AIMA sanctions-screening guide to review screening evidence and escalation decisions. These sound-practice resources sit alongside the applicable legal framework. For example, Hong Kong managers should separately assess the SFC AML/CFT requirements.

Before sharing records, confirm authority to disclose them, minimise personal data and use controlled access. Redact investor identifiers where appropriate. Compliance or counsel should decide how to handle privileged material and legally restricted reporting information; a DDQ request does not override confidentiality or tipping-off restrictions.

Check the response and keep it current

Before submission, have an authorised reviewer check the entity scope, template ID and edition, answer dates, evidence references and unresolved qualifications. State why a question is not applicable rather than leaving an unexplained blank. Keep the approved response, attachments and distribution record together.

If generative AI helps draft answers or supports a process described in the response, use our practical guide to AIMA’s generative AI checklist to define permitted data, testing and human approval. It draws on public sources and original implementation recommendations, not the restricted checklist.

Set an internal review owner and update the relevant answers when material facts change, including a new administrator, a revised strategy, a control failure or a policy change. Agree any investor update obligations separately. A DDQ review schedule does not determine your statutory KYC review or record-retention obligations.

Where the work sits with an administrator, our AIMA fund-administrator due-diligence guide explains how to organise an AML/KYC control review. Shadow KYC tests existing investor files against your fund’s AML policy and provides evidence-linked findings for oversight and remediation. Use those records to substantiate the AML/KYC statements in your DDQ; the manager’s authorised approvers remain responsible for the complete response.

If evidence gaps require operational work, AgentKYZ’s managed KYC services cover onboarding, remediation and periodic reviews under the client’s approved policy in Cayman, Singapore, Hong Kong and Jersey. To scope a review, bring the entity and jurisdiction, provider arrangement, approximate file count and known evidence gaps. Keep live investor records out of an initial enquiry.

Questions

What is an AIMA DDQ?

An AIMA DDQ is a due diligence questionnaire published by the Alternative Investment Management Association. Its investment-manager questionnaires help investors assess managers and funds. Separate questionnaires support the assessment of service providers, including fund administrators. A completed DDQ informs further investigation; it does not certify compliance or replace due diligence.

Where can I get an AIMA DDQ template?

Start with AIMA’s official DDQ library and investment-manager decision tree. AIMA provides template downloads to members and licenses use on selected third-party platforms, subject to the applicable terms and membership verification. If you are not a member, confirm the permitted route with AIMA and the requesting investor. This AgentKYZ guide does not provide or reproduce the official templates.

Which AIMA DDQ edition does this guide cover?

This guide references the final 2025 investment-manager edition, verified from AIMA’s public pages on 13 October 2026. The March 2025 release was a soft launch; AIMA’s transition page lists March-to-final blacklines dated 16 November 2025. The administrator page separately labels its resource “AIMA DDQ for Administrators (2017, 2025)”. These are public-source checks, not a review of every restricted template.

Who should complete an AIMA due diligence questionnaire?

The manager should appoint a coordinator and assign responses to the people who own the underlying work. Investor relations can coordinate the submission; investment, operations, finance, compliance and technology teams should validate their respective answers. Administrators can supply evidence about outsourced work. The manager’s authorised approvers should approve the final response.

Is an AIMA DDQ the same as investor KYC?

No. An investor uses a manager DDQ to investigate the fund manager and fund. The manager or fund’s responsible team performs KYC to investigate the investor. Records from investor onboarding, screening and ongoing reviews can support the manager’s DDQ statements about AML and KYC controls, but the processes serve different purposes.

Does completing an AIMA DDQ make a fund AIMA compliant?

No. “AIMA compliance” is not a regulatory status, and DDQ completion is not approval by AIMA or a regulator. Applicable legal obligations depend on the entity, jurisdiction and activities. The regulated entity retains compliance responsibility even when a service provider performs operational work.

Sources

AML and KYC evidence

Check the files behind your DDQ answers.

Shadow KYC tests existing investor files and records evidence gaps for your team’s review. Scope the files, policy and review period with us; your MLRO retains approval and your entity retains compliance responsibility.

AgentKYZ authored this guide independently. It is not an AIMA publication and does not imply AIMA endorsement, partnership or membership. AIMA’s questionnaires remain subject to its copyright and applicable terms of use. This guide is general information, not legal advice or a regulatory standard. DDQ completion does not establish “AIMA compliance” or regulatory approval. Verify the current official edition and applicable legal requirements with qualified advisers; the regulated entity retains compliance responsibility.