AIFMD 2: A harmonised loan origination framework for private credit funds in the EEA

AIFMD 2 marks a pivotal shift for EU private credit funds, introducing a harmonised framework for AIFMs of loan originating AIFs that replaces fragmented national rules with clear, consistent provisions that provide for a level-playing field. For private credit managers, opportunities are created to structure both open-ended evergreen and closed-ended direct lending AIFs across the EEA, with unified rules on governance, risk, liquidity, and investor protection.

Our article explains what this means in practice. We explain loan origination under AIFMD 2 and the new regime for AIFMs of “Loan Originating AIFs”, including calibrated leverage limits as well as the obligations applicable to any fund issuing loans. We also focus on the conditions for open-ended and semi-liquid strategies, where limited liquidity features, robust liquidity risk management and access to liquidity management tools will be central, alongside ESMA’s forthcoming RTS on redemption policies, stress testing and liquid asset buffers.

The Central Bank of Ireland has signalled its intention to align its AIF Rulebook without gold-plating and is currently consulting on a comprehensive AIF Rulebook refresh.

The harmonised AIFMD 2 regime and the updated AIF Rulebook will deliver enhanced options for credit fund design and structuring using Irish vehicles, and improved scalability for pan-EU lending platforms. For sponsors seeking to launch, refit or passport private credit strategies from Ireland, AIFMD 2 and the Central Bank’s proactive implementation plan, opens a clear route to growth in this area. Our full analysis highlights implementation timelines, structuring considerations and practical steps to capitalise on these opportunities.

Date published: 30 September 2025