knowledge 7 May 2026 |

AIFMD II: Strengthening Ireland’s Competitive Edge

Overview

Ireland has now transposed the AIFMD II Directive into national law through the publication of two statutory instruments: the European Union (Alternative Investment Fund Managers) (Amendment) Regulations 2026 and the European Union (Undertakings for Collective Investment in Transferable Securities) (Amendment) Regulations 2026 (the Implementing Regulations).

The Implementing Regulations came into operation on 1 May 2026, bringing Ireland’s regulatory framework into line with the EU-wide reforms and reinforcing the modern, transparent standards that have long underpinned the attractiveness of Irish-domiciled funds.

Key Areas of Reform

The Implementing Regulations update Ireland’s existing AIFMD and UCITS frameworks to reflect the reforms introduced by AIFMD II at EU level. The principal areas of reform include: the introduction of a harmonised regime for liquidity management tools (LMTs) applicable to UCITS and open‑ended AIFs; the establishment of an EU‑wide regulatory framework governing AIFs engaged in loan origination; and a series of related amendments addressing delegation arrangements, regulatory reporting obligations, data sharing between national competent authorities and depositary oversight requirements.

AIF Rulebook and UCITS Regulatory Updates

In addition to the Implementing Regulations, the Central Bank of Ireland (CBI) has also now published updates to its AIF Rulebook. These updates align domestic requirements applicable to Irish authorised AIFs and AIFMs with the AIFMD II reforms and introduce certain further flexible measures intended to support Ireland’s competitive position in relation to private assets.

Further updates to the domestic UCITS framework are also expected which will complete the Irish transposition of AIFMD II.

Next Steps

The Irish funds industry is well advanced in preparing for AIFMD II and the publication and commencement of the Implementing Regulations and AIF Rulebook marks the transition to an operational implementation phase. For open‑ended funds, managers should finalise their review of LMT governance arrangements, including the availability and calibration of tools, escalation procedures, and any corresponding updates to prospectus disclosure and internal policies and arrange for the relevant filings to be made with the CBI. For loan origination strategies, the new EU‑wide framework provides greater flexibility in relation to fund structures and will require managers to assess whether existing structures (including the use of subsidiaries or SPVs), origination and credit assessment processes, concentration limits and associated risk management documentation can be further enhanced under the revised regime. On a practical level, managers will need to be mindful of enhanced reporting and delegation requirements introduced by the new regime.

The transposition of the Implementing Regulations and the accompanying overhaul of Ireland's AIF Rulebook represent a significant step for the Irish funds industry. These reforms deliver a modernised, flexible, and internationally competitive private funds framework, underpinned by robust investor protection.

How We Can Assist

Should you have any questions regarding the Implementing Regulations, AIF Rulebook or changes to the UCITS framework, please do not hesitate to contact us.