knowledge 8 May 2026 |

Ireland’s QIAIF regime just got a serious upgrade

On 5 May 2026, the Central Bank of Ireland published its revised AIF Rulebook alongside the CP162 Feedback Statement.

The headline change from a fund financing perspective is that the long‑standing restriction preventing QIAIFs from providing third‑party guarantees has been removed.

What's changed

Since the AIF Rulebook was introduced in 2013, a QIAIF has been prohibited from acting as guarantor for any party other than itself or a wholly-owned subsidiary. In practice, this meant certain transactions - most commonly master-feeder subscription line financings, but also certain asset-level and NAV deals - required complex cascading pledge structures.

The March 2025 Q&A softened the position; CP162 has now removed it entirely, aligning the QIAIF regime with AIFMD II and the ELTIF Regulation.

Why it matters

Subscription lines and capital call facilities within ‘fund families’ can now be granted by Irish QIAIFs directly, without engineering a cascade.
Financing packages can be negotiated without ‘Ireland-specific’ workarounds.
Ireland's private markets offering becomes more competitive.

What sponsors and lenders should be doing now

Review existing QIAIF constitutional documents and prospectuses - direct guarantees will need to be properly disclosed and within the fund’s stated investment policy.
Revisit in‑flight financings where a cascade was being built purely for Irish regulatory reasons.
Keep cascades where other drivers apply (e.g. ERISA / commercial structuring).

Combined with the removal of the L-QIAIF chapter and the broader CP162 reforms, this is the most significant overhaul of the QIAIF regime since 2013. Ireland is now ideally positioned as a private markets fund domicile.

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.