A New Dawn for Ireland’s Private Funds Regime

What You Need to Know

On 5 May 2026, the Central Bank of Ireland (“CBI”) published its Feedback Statement to its Consultation Paper 162 (referred to as “CP 162”), together with a revised AIF Rulebook which comprehensively updates and enhances Ireland’s regulatory framework for alternative investment funds (“AIFs”).

The enhancements are the result of an extensive and collaborative industry consultation which closed in November 2025. They also coincide with the publication of the Irish statutory instrument to implement AIFMD 2.0¹, which came into effect on 1 May 2026.

The CBI’s reforms are designed to align the Irish domestic regulatory framework with AIFMD 2.0; to adopt recommendations from the Department of Finance’s Funds Sector 2030 review; and to ensure consistency with broader EU policy initiatives such as the Savings and Investment Union.

The revised AIF Rulebook represents a significant modernisation, simplification and clarification of the Irish rules governing Qualifying Investor AIFs (“QIAIFs”), Retail Investor AIFs, European Long-Term Investment Funds (“ELTIFs”), AIFMs and AIF depositaries.

In particular, the new regime introduces welcome flexibility and streamlined requirements to support the continued growth of Ireland as a domicile for private funds.

The key changes confirmed in the finalised rules are summarised below.

Direct Lending

The CBI has removed its legacy domestic regime for loan originating QIAIFs and will align instead with the corresponding loan origination framework under AIFMD 2.0.

This now ensures that Ireland is on a level regulatory playing-field with other leading EU domiciles of direct lending funds, and both EU and non-EU managers and sponsors will be able to avail of a broader range of private credit strategies using both the ICAV and ILP vehicles.

Greater Structuring Flexibility

Fund and Share Class Features

The AIF Rulebook now expressly provides for a variety of features commonly used by private funds, including capital commitments, side letters, differentiated investor participation (including excuse and exclude rights), and management participation for carried interest purposes.

Intermediate Investment vehicles

The CBI has removed its prescriptive rules on wholly owned subsidiaries of QIAIFs. The revised AIF Rulebook now provides that a QIAIF may invest through intermediate investment vehicles (including SPVs, aggregators, subsidiaries or co-investment vehicles) subject to prospectus disclosure on the use of such vehicles; appropriate due diligence by the AIFM prior to investment; and the AIFM having documented policies and procedures in place for active monitoring (in line with AIFMD requirements).

Guarantees / Financings

QIAIFs will no longer be constrained by limitations on guaranteeing the obligations of third parties. This is a significant development which will materially simplify fund financing arrangements for QIAIFs, and in particular will permit QIAIFs to participate in cross-collateralised borrowing arrangements within fund families.

Controlling Shareholdings

QIAIFs will no longer be restricted from acquiring shares carrying voting rights which enable them to exercise significant influence over the management of an issuing body.

Liquidity Management Tools

The revised AIF Rulebook now incorporates provisions which align product level rules with the new requirements of AIFMD 2.0 for the selection, disclosure and use of liquidity management tools (LMTs) applicable to open-ended (or open-ended with limited liquidity) QIAIFs.

AIF Management Companies

The CBI has deleted the chapter of the AIF Rulebook concerning the authorisation of AIF management companies. Certain governance and fitness and probity requirements will still apply to the directors of AIF management companies, which will be addressed in a separate Q&A.

ELTIF Enhancements

The ELTIF chapter of the AIF Rulebook has been updated to incorporate relevant updates from the QIAIF chapter, as well as to align with AIFMD 2.0.

Retail Investor AIF Reforms

The CBI has also introduced targeted changes to its Retail Investor AIF framework, to align with requirements under AIFMD 2.0. Further, more substantive changes will also be considered as part of a proposed broader review of Ireland’s AIF framework.

Further Information

These reforms represent a significant step forward for Ireland’s regulated AIF product framework, particularly in accommodating private fund structures. They will help to ensure that Ireland remains an attractive and competitive jurisdiction for AIF sponsors and investors.

Please reach out to your usual Maples contact, or to any of the partners below from our Irish Private Markets Group if you require any further information regarding the reforms or their implications for your fund structures.

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¹EU Directive 2024/927