On 21 October 2025, the European Securities and Markets
Authority (ESMA) published its draft Regulatory Technical Standards
(RTS) on open-ended loan-originating alternative investment funds
(AIFs). This marks a key step in the implementation of Directive
(EU) 2024/927 (AIFMD II), which updates the Alternative Investment
Fund Managers Directive (AIFMD) and Undertakings for Collective
Investment in Transferable Securities (UCITS) frameworks to
strengthen rules on delegation, liquidity risk, supervisory
reporting, depositary services, and loan origination.
Operationalizing AIFMD II: What Fund Managers Need to Know
The RTS sets out several key requirements for AIFMs managing
open-ended loan-originating AIFs: