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ARTICLE · 11 DECEMBER 2025

Further Clarifications On The ELTIF Regime

Arendt & Medernach
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The EU Commission published several answers concerning the amended Regulation (EU) 2015/760 (ELTIF Regulation) and thereby clarified a number of questions raised by national competent authorities...

LuxembourgFinance and Banking
Stefan Staedter
Stefan Staedter
Fiona De Watazzi
Fiona De Watazzi
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The EU Commission published several answers concerning the amended Regulation (EU) 2015/760 (ELTIF Regulation) and thereby clarified a number of questions raised by national competent authorities during the adoption process of Commission Delegated Regulation (EU) 2024/2759 (ELTIF 2.0 regulatory technical standards). The EU Commission's responses can be found on ESMA's website under its Q&A tool.

The EU Commission's long-awaited answers clarified, among others, the following points:

  • Member States may not add any further requirements in the field covered by the ELTIF Regulation. Article 1(3) of the ELTIF Regulation prohibits Member States from introducing requirements pertaining to the domiciliation or establishment of master or feeder ELTIFs. Member States may not impose requirements pertaining to the nationality, domiciliation or location of the ELTIF or its manager, including for ELTIFs packaged in insurance products or embedded in pension/savings plans, as an

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