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Impact Analysis of the Proposed Amendments to the Central Bank of Ireland’s Alternative Investment Fund Rulebook (AIF Rulebook)
18/11/2025During September 2025, the Central Bank of Ireland (“Central Bank”) issued a substantive Consultation Paper, 162, setting out proposed amendments to the AIF Rulebook, as a regulatory corollary of certain legislative provisions contained in the AIFMD II Directive and in response to engagement with industry over recent years, including a consideration of the recommendations contained in Funds Sector 2030 Final Report issued by Ireland’s Department of Finance.
The proposed amendments are in line with the Central Bank’s strategic priorities of safeguarding, transforming, and engaging with industry, whilst maintaining financial stability and protecting investor interests. They are a positive advancement for Ireland’s private asset fund offering, if and when adopted in an adjusted AIF Rulebook. An adjusted AIF Rulebook which adopts the proposed amendments can better align regulatory rules with industry practices and global investment fund features, should make Ireland more attractive to international capital, and can provide further transparency for asset managers and investors
Impact Analysis
The impact of some of the material proposed amendments to the AIF Rulebook are outlined below:
| Suggested Amendment | Description | Likely Impact |
|---|---|---|
| Removal of the Loan-Originating QIAIF (L-QIAIF) chapter and alignment with the EU loan-origination framework. | Folding L-QIAIF requirements into the general Qualifying Investor AIF framework, thereby aligning with the revised AIFMD II. | More standardised loan fund product offerings, faster product development and a likely wave of new loan funds (including open-ended funds with LMTs). |
| Removal / relaxation of the prohibition on QIAIFs providing third-party guarantees and certain security arrangements. | QIAIFs may act as guarantor or provide security in a broader set of circumstances than heretofore. | Increased fund finance and private equity structuring involving QIAIFs, with a related increase in deal flexibility (bridge financings, facility backstops, multi-tiered financings, fund-level support of portfolio company financings). |
| Permitting asset-mixing and broader lending/activity scope. | This flexibility includes open-ended loan funds with appropriate liquidity management and expanded leverage allowances under the QIAIF framework. | Broader strategy scope, whereby managers can combine loan origination with other private asset strategies inside a single umbrella QIAIF (where allowed). Open-ended loan funds with LMTs can become commercially feasible and the leverage changes may permit slightly higher leverage for some strategies — enabling larger, more efficient books for credit strategies. |
| Clearer expectations and new disclosure requirements on Liquidity Management Tools (LMTs). | The focus of this suggested amendment is on liquidity management for open-ended or semi-liquid strategies. | Higher transparency and operational discipline can increase investor-level confidence in semi-liquid structures with increased documentation and control requirements for managers. |
By Byrne Wallace Shields, Ireland, a Transatlantic Law International affiliated firm.
For further information or for any assistance please contact ireland@transatlanticlaw.com.
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