The updated Alternative Investment Fund Managers Directive (AIFMD II) represents a significant milestone in the EU regulatory framework for alternative investment funds. Its purpose is to drive greater transparency, strengthen investor protection, and enhance market resilience.
What is changing under AIFMD II?
- Loan origination - new rules for loan-originating AIFs include leverage limits, risk retention on transferred loans, and restrictions on lending to related parties.
- Delegation and substance - stricter governance standards require detailed delegation reporting and at least two senior individuals based in the EU.
- Liquidity management- open-ended AIFs must adopt at least two liquidity management tools with clear activation and deactivation policies.
- Reporting and disclosure - expanded obligations cover delegation, liquidity management, and loan portfolios, with enhanced investor transparency on costs and risks.
- UCITS alignment - parallel requirements for UCITS ensure consistency across retail and institutional funds.
How we help you stay ahead
Our team combines regulatory insight with practical solutions to help you meet obligations and seize opportunities. We provide:
- Readiness assessments and gap analysis
- Governance and delegation frameworks
- Liquidity and risk management tools
- Cross-border compliance strategies
- Ongoing advisory and training
We will help you navigate complexity and turn compliance into a competitive advantage.
Key contacts
Contact our Funds team to discuss your AIFMD II strategy
Michaela Arter
Partner
United Kingdom
Julian Brown
Partner
United Kingdom
Codrina Constantinescu
Partner
Luxembourg, Luxembourg
Trevor Dolan
Partner
Dublin, Ireland
Phil Spyropoulos
Partner
United Kingdom
Lindi Rudman
Legal Director, Head of FS+
United Kingdom
Bernard Elslander
Principal Associate
Luxembourg, Luxembourg
Mercedes Pérez Cortejoso
Principal Associate
Luxembourg, Luxembourg
Latest Insights
- legal updatesIreland: QIAIFs can now grant loans and guarantees
- legal updatesIreland: AIFMD II Implementing Measures
- legal updatesIreland: Investment Funds Update - April 2026
- legal updatesEU: ESMA final report on open-ended loan-originating AIFs