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ARTICLE · 17 OCTOBER 2025

Update From Our Partner Firm Elvinger US: AIFMD II - Key Changes And Implications For AIFMs

ELVINGER HOSS PRUSSEN, société anonyme
Explore more from ELVINGER HOSS PRUSSEN, société anonyme

With exactly 6 months to go until the AIFMD II transposition deadline (i.e., 16 April 2026), the countdown is on.

LuxembourgFinance and Banking
Elvinger Hoss Prussen
Elvinger Hoss Prussen

With exactly 6 months to go until the AIFMD II transposition deadline (i.e., 16 April 2026), the countdown is on. Without aiming to provide an exhaustive summary, here are 10 key takeaways you should have on your radar regarding the upcoming changes grouped in two categories: five changes directly impacting products set up by US Sponsors (*) and five updates having an indirect impact only (-).

1. Loan Origination European Passport and Framework (*)

AIFMD II ensures that alternative investment funds (AIFs)/alternative investment fund managers (AIFMs) may engage in loan origination at EU level (which was previously determined at Member State level) (the so-called "loan origination passport") and introduces a comprehensive regime for funds which originate (any) loans (directly or indirectly) (FoLs) and additional requirements for "loan-originating" AIFs (LoFs – i.e., AIFs whose main investment strategy is to originate loans/of which loans constitute more than 50

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