Central Bank Updates AIFMD Q&A

On 7 March 2025, the Central Bank of Ireland (the "Central Bank") published the 50th edition of its AIFMD Questions and Answers ("Q&A"), which provides important clarifications on the application of the prohibition on Alternative Investment Funds ("AIFs") acting as guarantors for third parties under the Central Bank's AIF Rulebook. It also includes guidance on the application of two existing rules to loan originating AIFs.

We welcome these helpful clarifications and understand that the Central Bank has issued them on an interim basis pending a proposed consultation this year on a wider review of the AIF Rulebook. Such consultation is intended to address the recommendation in the Government's Fund Sector 2030 Final Report, published in October 2024, that to support further growth of private assets, the Central Bank should review its AIF Rulebook and associated requirements that impact on the establishment of private asset funds in Ireland.