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ARTICLE · 05 FEBRUARY 2026

Central Bank Implements A Streamlined Authorisation Process For AIFMs Engaging In Loan Origination

McCann FitzGerald LLP
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McCann FitzGerald LLP

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On 29 January 2026, the Central Bank of Ireland (the "Central Bank") published a note detailing the new authorisation-extension process for alternative investment...

IrelandFinance and Banking
Iain Ferguson
Iain Ferguson
Mark White
Mark White
Morgan Dunne
Morgan Dunne
Ciara O'Leary
Ciara O'Leary

Introduction

On 29 January 2026, the Central Bank of Ireland (the "Central Bank") published a note detailing the new authorisation-extension process for alternative investment fund managers ("AIFMs") engaging or seeking to engage in loan origination through their alternative investment funds ("AIFs") under management, (here). The note provides detail as to how such AIFMs can engage with the Central Bank in order to extend their existing authorisations in advance of the national implementation of Directive 2024/927/EU ("AIFMD II") by 16 April 2026.

Scope and Requirements

The new loan origination rules under AIFMD II apply to all AIFs that originate loans and their respective AIFMs, with additional requirements applying to those AIFs which have loan origination as their principal strategy. The origination of loans on behalf of an AIF is an additional AIFM function requiring authorisation by the Central Bank and the Central Bank is requiring these AIFMs

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