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ARTICLE · 02 FEBRUARY 2026

Loan Originating AIFMs | AIFMD 2.0 Compliance

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This is for AIFMs currently managing loan originating Qualifying Investor Funds and is designed to enable them to meet the requirements of AIFMD 2.0 by 16 April 2026.

IrelandFinance and Banking
John Aherne
John Aherne
Vincent Coyne
Vincent Coyne
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The Central Bank of Ireland is implementing a streamlined authorisation process for alternative investment fund managers (AIFMs) which engage in loan origination.

This is for AIFMs currently managing loan originating Qualifying Investor Funds and is designed to enable them to meet the requirements of AIFMD 2.0 by 16 April 2026.

AIFMD 2.0 and loan origination

AIFMD 2.0 introduces a harmonised framework for loan origination by AIFs and AIFMs across the EU. These rules must be transposed into national law by 16 April 2026 and apply to all AIFs that originate loans.  There are additional requirements for Loan Originating AIFs (LO AIFs) whose main strategy is lending or whose originated loans represent at least 50% of their net asset value.

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