Overview

On 5 May 2026, the Central Bank of Ireland (the “Central Bank“) published an updated AIF Rulebook, together with its Feedback Statement on Consultation Paper 162, which it issued in September 2025 to gather industry views on amendments to the regulatory framework for Irish-authorised alternative investment funds (“AIFs”).

The AIF Rulebook consolidates into a single document the conditions imposed on Irish-authorised AIFs, AIFMs and their depositaries.

The CP162 review was initiated to align the national regulatory framework with Directive (EU) 2024/927 (“AIFMD II”), to respond to recommendations in the Irish Government’s Fund Sector 2030 Final Report and to ensure consistency with broader policy initiatives, including the EU Savings and Investment Union.

The Central Bank also recognised that the funds industry has undergone considerable change since the AIF Rulebook was first introduced and that updates are necessary to take account of market developments, enhance regulatory effectiveness and provide additional clarity regarding the Central Bank’s expectations for regulated AIFs and related fund service providers.

Following on from last week’s publication of the Irish implementing measures for AIFMD II, the conclusion of this wide‑ranging review of the AIF Rulebook represents a significant milestone in Ireland’s implementation of AIFMD II.

For more on Ireland’s implementation, see our recent update: Ireland implements AIFMD II and UCITS VI | Arthur Cox LLP.

Key changes to the AIF Rulebook

• Qualifying Investor AIFs (“QIAIFs”)

The legacy loan origination chapter has been removed, aligning the AIF Rulebook with the new EU loan origination framework under AIFMD II.

As proposed in the consultation, the restriction on the provision by QIAIFs of third-party guarantees has been removed, which will simplify how QIAIFs put in place subscription line, asset level and other fund financing arrangements across more complex private fund structures and fund families.

In addition, the revisions to the AIF Rulebook include a range of technical and clarificatory amendments, including simplification of intermediary investment vehicle requirements and aligning the AIF Rulebook with market standard product features for private asset funds and other types of AIFs.

• Performance fee verification

The Central Bank has updated its approach to performance fee verification, such that an AIF must ensure that the depositary, or approved competent person, verifies that procedures have been effectively implemented to ensure that performance fees are calculated in accordance with the AIF’s governing documents.  The AIF must now ensure that its AIFM provides the depositary/competent person with all necessary information regarding the calculation of the performance fee in advance of any such fees being paid.

• European Long-Term Investment Funds (“ELTIFs”)

The ELTIF chapter in the AIF Rulebook has similarly been updated to align with certain changes to the QIAIF chapter as well as with AIFMD II, including rules on liquidity, performance fees, share classes and disclosure.

• Retail Investor AIFs

The Retail Investor AIF chapter has been revised to align with AIFMD II, with key developments including: the removal of the restriction on granting loans (thereby enabling the establishment of loan-originating Retail Investor AIFs); the introduction of harmonised rules on liquidity management tools; revised performance fee verification expectations; and the introduction of stress testing requirements for Money Market Funds.

• AIFMs

The Central Bank had proposed an update to financial reporting by AIFMs, where they would be required to produce half-yearly reports covering the second half of the financial year. Respondents to the consultation disagreed with the changes proposed as there could be an increased reporting burden, so the Central Bank has removed the proposed requirement.

• AIF Management Company chapter

Chapter 4 (AIF Management Company Requirements) of the previous AIF Rulebook has been deleted.  Since all AIFs must appoint an AIFM, and the AIFM is the legally responsible entity under AIFMD, there is no regulatory requirement to also require an AIF management company to seek its own authorisation from the Central Bank. Requirements relating to governance and director fitness for an AIF management company are still applicable (e.g. the Central Bank’s Fitness and Probity regime) and the Central Bank proposes to issue a Q&A to address queries relating to governance and director fitness requirements for AIF management companies.

Next steps

In light of the updated AIF Rulebook, firms should review the revised requirements carefully and assess the impact on their fund structures, operational arrangements, and documentation. We expect the Central Bank to issue updated AIFMD Q&A, guidance and application forms, reflecting the new requirements, shortly. The Central Bank has indicated that a broader review of the AIF framework is expected to take place in the coming year.

For more information and advice on the changes to the AIF Rulebook, please contact any member of our Asset Management and Investment Funds Group.