The revised Directive brings clarity in some areas, new obligations in others, and fresh opportunities for managers who are prepared. Angel Ramon Martinez Bastida and Maria Von Oldenskiöld recap the key changes private markets managers should be focusing on ahead of this month’s implementation deadline.
With the Alternative Investment Fund Managers Directive (AIFMD) 2.0 due to be transposed into national law across EU member states by 16 April 2026, private markets managers are entering a defining period of regulatory change. While the amendments were adopted at EU level in April 2024, their practical impact will be shaped by national transposition choices and supervisory practice.
In key alternative fund domiciles such as Luxembourg and Ireland, AIFMD 2.0 largely confirms existing market practice in some areas, while introducing material changes in others — most notably around loan origination, delegation oversight, liquidity management tools and disclosures. Managers should therefore move beyond a purely EU‑level reading of the Directive and assess how the new rules will apply in their chosen domicile, taking into account local regulatory expectations, transitional arrangements and operational realities.
Below, we break down the most relevant changes for managers operating in Luxembourg and Ireland, what they mean in practice, and how third‑party fund administrators can support implementation.
For the first time, AIFMD 2.0 establishes an EU‑wide regime governing loan origination by alternative investment funds (AIFs), representing a significant development for private credit strategies.
AIFMD 2.0 introduces:
In Luxembourg, the draft transposition confirms that AIFs are explicitly permitted to originate loans, while maintaining the long‑standing prohibition on consumer lending. Importantly, Luxembourg adopts the EU‑level leverage, concentration and risk‑retention limits without gold‑plating, providing legal certainty for private credit managers.
In Ireland, the Central Bank is using AIFMD 2.0 as an opportunity to re‑engineer the AIF Rulebook, replacing the existing domestic loan‑origination regime with the new EU framework. This includes the removal of the L‑QIAIF category and enabling loan origination across the wider QIAIF regime, again without additional local overlays.
Private credit managers will need to reassess fund structuring, liquidity management, leverage policies and operating models to ensure alignment with the new framework. In both Luxembourg and Ireland, loan‑originating AIFs are in practice likely to remain predominantly closed‑ended, except where managers can clearly demonstrate that their liquidity risk management framework supports an open‑ended structure.
Managers should also factor in the five‑year grandfathering regime available for certain pre‑existing loan‑originating AIFs and assess carefully whether subsequent capital raising may affect eligibility.
A third‑party fund administrator with private credit expertise can support managers by:
Read more here.
AIFMD 2.0 does not prohibit delegation, but it extends and clarifies its perimeter, reinforcing supervisory expectations around oversight, governance and substance.
Delegation rules now apply to all Annex I functions and permitted ancillary services. AIFMs must demonstrate that delegates are appropriately qualified, that delegation arrangements are monitored effectively, and that the AIFM retains sufficient internal resources and decision‑making capacity.
In Luxembourg, the transposition clarifies that delegation requirements apply consistently across a broad range of arrangements, including group entities, co‑investment vehicles and carried interest structures, reinforcing existing CSSF expectations.
In Ireland, the Central Bank is aligning its supervisory approach with the enhanced AIFMD 2.0 framework, focusing on effective oversight and management substance, rather than dismantling well‑governed delegation models.
The key shift for managers is evidencing how delegation works in practice, rather than eliminating it. Governance frameworks, oversight processes and documentation will be critical in demonstrating compliance.
Experienced administrators and AIFM service providers can help managers:
AIFMD 2.0 introduces a harmonised list of liquidity management tools for open‑ended AIFs.
AIFMs managing open‑ended AIFs must select at least two appropriate LMTs from a prescribed list and maintain documented procedures for their activation and deactivation. Certain activations trigger mandatory regulatory notifications.
In Luxembourg, the harmonised list applies as a minimum standard, with additional tools permitted subject to governance and disclosure requirements.
In Ireland, the revised AIF Rulebook aligns closely with the AIFMD 2.0 framework, with an increased focus on liquidity governance and transparency for open‑ended funds.
Closed‑ended funds remain largely unaffected, but managers with open‑ended strategies should ensure liquidity frameworks, disclosures and escalation procedures are fully aligned.
Administrators can assist with:
Depositary arrangements were a key area of focus during the AIFMD 2.0 negotiations. While the revised framework stops short of introducing a full EU depositary passport, it introduces targeted flexibility and reinforces the importance of national supervisory discretion in how these rules apply in practice.
In the end, AIFMD 2.0 introduces limited flexibility at EU level, with national competent authorities retaining full discretion over whether and how this flexibility is applied.
In Luxembourg, the option to appoint a depositary established in another member state has not been adopted. Luxembourg AIFs must therefore continue to appoint a Luxembourg‑established depositary.
In Ireland, a more flexible approach is being explored within the confines of the Directive, although approvals remain case‑by‑case and subject to regulatory justification.
Managers should not assume that cross‑border depositary appointments will be available and should engage early with service providers to assess feasibility.
Integrated depositary and administration providers can support regulatory engagement and operational implementation.
Read more here.
AIFMD 2.0 places increased emphasis on transparency and supervisory reporting, expanding both the scope and granularity of information to be provided to regulators and investors. While further detail will follow through Level 2 measures, the direction of travel is clear for managers across jurisdictions.
The investor disclosure and regulatory reporting requirements expanded include enhanced cost transparency, delegation reporting, liquidity disclosures and, for loan‑originating AIFs, portfolio‑level reporting
The European Securities and Markets Authority (ESMA) is mandated to develop new Level 2 measures, including an updated Annex IV template.
Managers should treat current requirements as a baseline, with further technical detail expected ahead of implementation, and begin mapping data and reporting impacts early.
To meet AIFMD 2.0’s enhanced reporting expectations, managers need a trusted fund administrator that closely monitors regulatory developments and delivers regulatory reporting services aligned with the latest requirements, including updated Annex IV and evolving supervisory expectations.
Across Luxembourg and Ireland, managers should already be:
Aztec is uniquely positioned to support managers through AIFMD 2.0, offering integrated AIFM, depositary and administration services, backed by regulatory specialists closely involved in the interpretation and implementation of the revised Directive.
If you would like to discuss how AIFMD 2.0 affects your structures in Luxembourg or Ireland, please contact us.
24 March 2026 Paul Conroy
