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ARTICLE · 24 OCTOBER 2025

ESMA Publishes Final Report On Open-ended Loan-originating AIFs

Dillon Eustace
Dillon Eustace
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On 21 October 2025, ESMA published its final report containing conditions that it proposes AIFMs managing open-ended loan origination funds must take into account for the purposes of liquidity management (Final Report).

IrelandFinance and Banking
Etain De Valera
Etain De Valera
Cillian Bredin
Cillian Bredin
Derbhil O'Riordan
Derbhil O'Riordan
David Walsh
David Walsh
Shane Coveney
Shane Coveney
Joe O'Doherty
Joe O'Doherty
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What has ESMA published?

On 21 October 2025, ESMA published itsfinal report containing conditions that it proposes AIFMs managing open-ended loan origination funds must take into account for the purposes of liquidity management (Final Report). This follows a consultation process which it ran from December 2024 to March 2025 (Consultation) 1.

As readers may be aware, a new common set of EU rules for AIFMs managing loan-originating AIFs comes into effect in April 2026. Under the new rules, loan-originating AIFs must be structured as closed-ended funds unless the AIFM can satisfy its home regulator that its liquidity management approach is aligned with the investment strategy and redemption policy of the fund.

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