The regulatory landscape for Irish UCITS and AIFs continues to evolve as the industry approaches the 16 April 2026 deadline for the transposition of AIFMD II and UCITS VI (Directive (EU) 2024/927). Two notable publications from the Central Bank of Ireland (the “Central Bank”), alongside the publication of the final Liquidity Management Tools (“LMT”) Regulatory Technical Standards (“RTS”) in the Official Journal today (27 February 2026), bring additional clarity to firms’ implementation planning.

Updated Authorisation Process for AIFMs managing Loan‑Originating AIFs

As we advised last month, the Central Bank published a streamlined authorisation process for AIFMs that manage loan‑originating AIFs. This Process Note was designed to address the new requirements under AIFMD II, which designate loan origination as an additional Annex I activity requiring additional regulatory permission. The Central Bank today expanded this process for AIFMs managing authorised and unauthorised loan‑originating AIFs. Different requirements apply to (i) Central Bank authorised AIFMs which currently manage Qualifying Investor AIFs which originate loans, as well as non-Irish AIFs and/or unauthorised Irish AIFs which originate loans; and (ii) all other authorised AIFMs.

Under this process, Central Bank authorised AIFMs seeking to continue managing loan‑originating AIFs beyond April 2026 must submit two letters to the Central Bank:

• A formal request for authorisation to provide the function of originating loans; and
• A detailed letter listing each AIF that originates loans (including dates of establishment and domicile), the policies, procedures and processes governing loan origination, and an explanation of how these align with AIFMD II requirements.

Crucially, the Central Bank has confirmed it will take a proportionate approach for AIFMs already managing loan‑originating QIAIFs, recognising that these managers typically already operate under a stringent governance regime which often exceeds what AIFMD II will require. This approach is intended to avoid unnecessary duplication while ensuring firms achieve the required authorisation by 16 April 2026, given that AIFMD II includes no grandfathering provisions for AIFMs.

The Process Note confirms that following authorisation of Central Bank authorised AIFMs managing EU AIFs established in other Member States, the Central Bank will transmit a notification to the relevant host competent authority.

All other authorised AIFMs wishing to be authorised to perform the activity of originating loans on behalf of AIFs must submit the following to the Central Bank:

• A formal request for authorisation to provide the function of originating loans;
• A detailed letter listing the domicile of non-Irish AIFs that originate loans, a confirmation regarding unauthorised Irish AIFs which originate loans, the domiciles, the policies, procedures and processes governing loan origination, and an explanation of how these align with AIFMD II requirements; and
• Copies of the policies, procedures and processes governing loan origination for review and consideration by the Central Bank.

Streamlined Filing Process for updates to UCITS/AIF Documents

The Central Bank today issued a Process Clarification, providing a roadmap for updating and filing fund documentation for both UCITS and AIFs under UCITS VI and AIFMD II, respectively.

This process applies to existing funds only and is designed to facilitate timely updates to:

• Prospectuses and supplements, and
• Constitutional documents

reflecting AIFMD II and UCITS VI and the revised AIF Rulebook/UCITS VI and the forthcoming updated Central Bank UCITS Regulations.

Key Points

• Scope of changes permitted
  The streamlined process may be used for non‑material amendments only. Updates impacting the investment objective, policy, or strategy remain subject to a full post‑authorisation review.
• Submission requirements
  Managers must submit final revised documentation along with an attestation confirming that no material changes (such as investment objective alterations or SFDR reclassifications) are being made. SFDR reclassifications are explicitly excluded from the streamlined process.
• Procedural instructions
  Submissions in the required format must be sent to a dedicated mailbox for automated noting. The Central Bank may conduct sample reviews at a later date.
• Filing window
  The streamlined filing window opens on 2 March 2026.

This filing process aims to help UCITS management companies and AIFMs manage documentation updates efficiently, particularly given the breadth of Level 1 and Level 2 changes coming into force.

Final LMT RTS published in the Official Journal

A major milestone in the implementation of AIFMD II and UCITS VI is the final RTS on LMTs (for UCITS and AIFs), which were published in the Official Journal of the European Union earlier today. Both RTS remain unchanged from those adopted by the European Commission in November 2025 and introduce the most detailed EU‑wide liquidity management framework to date.

The RTS will apply from 16 April 2026, with a 12‑month transition period for existing UCITS and AIFs. For more details on the RTS see our related update: European Commission adopts technical standards on liquidity management tools under AIFMD and the UCITS Directive

For more information and advice on the changes to AIFMD or the UCITS Directive, please contact any member of our Asset Management and Investment Funds Group.