Contributing Firms:
Loan Originating AIFs
AIFMD 2.0 introduces a new regulatory framework for loan-originating AIFs and is set to come into force on 16 April 2026, creating a harmonised framework for loan originating activities across the European Union. What possibilities will exist under this framework for innovation by fund managers and promoters and what opportunities does this present for Ireland-based AIFs?

Oisin McClenaghan, Partner, Investment Funds, Ogier:
Oisin McClenaghan
Oisin McClenaghan
From an Irish perspective, the new AIFMD II loan origination regime is widely welcomed and a positive development, introducing new flexibilities into the Irish framework for AIFs directly engaging in loan origination.

The new regime replaces in full the legacy Irish L-QIAIF regime and is being implemented in Ireland without any gold plating, also greatly welcomed. Coupled with the compelling advantages of the Irish/US tax treaty, we expect continued significant growth in Irish loan origination AIFs in the coming years.
Ailbhe MacManus
Ailbhe MacManus


Ailbhe MacManus, Partner, EY Ireland: AIFMD 2.0 will unlock significant innovation opportunities in Ireland as all AIFs will now be able to engage in loan originating activities under the harmonised AIFMD 2.0 rules. Previously a fund manager had to launch a dedicated L-QIAIF to originate loans. Now, any AIF, such as one structured for private equity or infrastructure, can include loan origination in its strategy. As a result of this flexibility, we expect to see an increase in popularity of hybrid funds.

This is a great opportunity for Ireland as it removes fragmented national rules across the EU and replaces them with a clear and consistent regime that provides for a level-playing field across key fund jurisdictions such as Ireland and Luxembourg. The timing of this aligns very well with Ireland’s desire to increase its share of the private assets market.

Ireland should leverage this momentum by positioning itself as the leading domicile for AIFs, supported by ongoing government and regulatory initiatives.