The Central Bank of Ireland (CBI) has published the revised AIF Rulebook and its feedback statement to Consultation Paper 162 (CP162). In addition, the transposition of Directive (EU) 2024/927 (AIFMD II) into Irish law has been effected through a Statutory Instrument amending the European Union (Alternative Investment Fund Managers) Regulations 2013 (AIFM Regulations)[1].
Together these represent the most significant update to the Irish regulatory framework for alternative investment fund managers (AIFMs) and alternative investment funds (AIFs) in over a decade.
The revised AIF Rulebook applies with immediate effect from 5 May 2026 to Irish authorised AIFs and AIFMs and to non-Irish AIFMs to the extent provided for in the Rulebook where they manage or market Irish authorised AIFs or are otherwise subject to CBI supervisory requirements.
As noted in our previous insight on the launch of CP162 in September 2025, the consultation proposed a comprehensive re-write of the AIF Rulebook, structured around three policy objectives of the AIFMD II transposition, the European Commission’s Savings and Investment Union (SIU) goal of reducing regulatory burdens and improving the accessibility of financial products and the Department of Finance Funds Sector 2030 Review objectives, which included a recommendation to further support the growth of private assets. The CBI has implemented substantially all of the key proposals set out in CP162 while also taking account of industry feedback.
AIFMD II rules on delegation, liquidity management tools, loan origination, reporting and depositaries have been implemented through the revised AIFM Regulations.
Revised AIF Rulebook highlights
Qualifying Investor AIFs (QIAIFs)
- The standalone loan origination QIAIF or “L-QIAIF” category has been removed, aligning Ireland with the harmonised EU loan origination framework under AIFMD II, implemented through the AIFM Regulations.
- The former restriction on QIAIFs granting loans or acting as a guarantor for third parties has been removed, subject to compliance with the AIFMD II loan-originating AIF provisions in the AIFM Regulations.
- Non-EU AIFMs may now manage closed-ended loan-originating QIAIFs, subject to compliance with the provisions applicable to loan originating AIFs in the AIFM Regulations.
- The AIF Rulebook now clarifies that both open-ended and closed-ended QIAIFs may allocate assets at share class level, provided the arrangement does not pursue a separate investment objective, operate as a de facto sub-fund, or circumvent other share class requirements. Existing CBI guidance is also now codified and extended, expressly permitting for QIAIFs the issuance of interests in a QIAIF other than at NAV, and the issuance of interests in a QIAIF which provide for differentiated participation in underlying investments to facilitate the operation of excuse and exclude provisions, stage investing, and management participation or carried interest arrangements.
- The former restriction on QIAIFs acquiring voting rights conferring significant influence over an issuing body is removed.
- The subsidiary regime has been broadened into an “intermediary investment vehicles” framework, which covers SPVs, aggregators and co-investment structures. Prior CBI approval and the QIAIF director board majority requirement is replaced by disclosure, due diligence and ongoing AIFM oversight obligations supported by documented policies and procedures.
- QIAIFs can operate a capital commitment mechanism to provide for those QIAIFs to account for the contribution of the committed capital towards the minimum subscription of €100,000. The list of entities that the QIAIF can grant an exemption from the minimum subscription requirement has been extended to include the AIFM or other entity within the AIFM’s group and those entities that provide advisory services (discretionary or non-discretionary) to the AIFM.
- Updated performance fee verification requirements apply. The QIAIF must ensure that the depositary or a competent person appointed by the AIFM and who is approved for the purpose by the depositary, verifies that procedures have been effectively implemented to ensure that any performance fees payable and accrued pursuant to the QIAIF’s performance fee payment cycle are calculated in accordance with the QIAIF’s governing documents. The QIAIF must also ensure that its AIFM provides the depositary/competent person with all necessary information regarding the calculation of the performance fee in advance of any such fees being paid.
- The AIF Rulebook supplements the revised AIFM Regulations on LMTs for open-ended QIAIFs or open-ended QIAIFs with limited liquidity, including the ability for AIFMs to select additional LMTs beyond those specified in Annex V of AIFMD. AIFMs must disclose at least two LMTs in governing documents and consider selecting at least one quantitative based LMT (redemption gate, extension of notice period, redemption in kind) and at least one anti-dilution tool (swing pricing, redemption fee, dual pricing, anti-dilution levy). General LMT notification to the CBI has been removed in light of the CBI’s daily reporting requirements but immediate notification remains for activation or deactivation of suspensions and specific requirements apply for redemption gates, side pockets and suspensions.
Further private asset enhancements include removal of the current market value cap on warehoused assets, simplified in specie redemptions, deletion of the 10% redemption proceeds retention threshold and preferential treatment provisions providing a disclosure-based framework for side letter arrangements.
Retail Investor AIFs (RIAIFs)
The changes to the RIAIF chapter are more limited in scope, reflecting the CBI’s decision to focus this update on AIFMD II alignment while deferring a broader review of the RIAIF framework in the context of the SIU initiative. Key changes include the removal of the restriction on granting loans, new LMT requirements, revised performance fee verification procedures, more streamlined reporting and the introduction of stress testing requirements for Money Market RIAIFs.
European Long-Term Investment Funds (ELTIFs)
The ELTIF chapter has also been updated in several areas to align with the updated QIAIF framework. Key enhancements include new LMT provisions for open-ended ELTIFs, clarification of performance fee requirements, preferential treatment disclosure obligations, requirements relating to charity share classes, extension of entities exempt from minimum subscription requirements and consolidated and simplified voting procedures for changes to duration, investment objective and fees.
What’s next?
The CBI has indicated that it intends to carry out a broader review of the AIF framework in the coming year, which will include further consideration of the RIAIF chapter and of the approach to unregulated funds.
Fund managers should review existing documentation and operational frameworks to ensure alignment with the revised AIF Rulebook and updated AIFM Regulations.
For more information, please contact any member of the Asset Management & Investment Funds team.
Date published: 8 May 2026
[1] S.I No. 181 of 2026 – European Union (Alternative Investment Fund Managers) (Amendment) Regulations 2026.
