The long‑anticipated Irish implementing measures for Directive (EU) 2024/927 (known as “AIFMD II” or “UCITS VI”) have now been published, with the making of the implementing statutory instruments (S.I. No. 181/2026, the “AIFMD II Regulations” and S.I. No. 182/2026, the “UCITS VI Regulations“, together the “New Regulations”), which come into operation today (1 May 2026).
This update outlines the changes contained in the New Regulations and considers the practical implications for AIFMs, UCITS management companies and fund boards.
Legislative framework: the implementing statutory instruments
The New Regulations give effect in Irish law to the amendments introduced by AIFMD II/UCITS VI at EU level in 2024 and embed the Directive’s core reforms at national level, including the key changes relating to:
- liquidity management tools for both UCITS and open-ended AIFs; and
- the harmonised EU framework for AIFs engaged in loan origination.
Revised AIF Rulebook: alignment and modernisation
Alongside the AIFMD II Regulations, the Central Bank will shortly publish a revised version of its AIF Rulebook, consolidating and updating the domestic requirements applicable to Irish‑authorised Alternative Investment Funds (“AIFs“) and Alternative Investment Fund Managers (“AIFMs“). In addition to AIFMD II-related updates, the revised AIF Rulebook gives effect to the recommendations of the Irish Government’s Fund Sector 2030 Final Report supporting investments in private assets and makes a number of other significant modernising and streamlining changes to Ireland’s AIF regime. For more on the 2025 consultation process, see our update: Central Bank issues consultations on proposed updates to its AIF Rulebook and the Central Bank UCITS Regulations | Arthur Cox LLP
The revised Rulebook continues to operate as a single, consolidated source of fund‑level requirements, covering retail investor AIFs (“RIAIFs”), qualifying investor AIFs (“QIAIFs”), European Long-Term Investment Funds (“ELTIFs”), AIFMs and AIF depositaries. The key changes in the updated framework include those required to align domestic rules with AIFMD and changes introduced through the CP162 consultation process provide greater flexibility in relation to fund structures, subsidiaries and other intermediate investment vehicles, and fund financing arrangements, while retaining core investor protection safeguards.
Central Bank UCITS Regulations
Following the publication of the revised AIF Rulebook, the Central Bank has signalled that revised Central Bank UCITS Regulations will be published to align the domestic UCITS regime with the revised EU framework and complete the Irish implementation package.
Practical implications
The New Regulations and the awaited revised AIF Rulebook and Central Bank UCITS Regulations will complete the domestic AIFMD II/UCITS VI framework. While many firms have been preparing for the new requirements for some time, the focus now turns to any remaining regulatory filings (e.g., to fund documentation and, where relevant, the filing of policies and procedures relating to liquidity management tools) and embedding the new framework.
As outlined in our recent update Central Bank updates on AIFMD II/UCITS VI processes and EU publication of final LMT RTS | Arthur Cox LLP, the Central Bank has put in place a streamlined filing process to facilitate orderly updates to fund documentation arising from AIFMD II and UCITS VI, including prospectus and constitutional document amendments. It has also communicated its requirements relating to the filing of policies and procedures relating to liquidity management tools by AIFMs and UCITS management companies and their funds under management.
Although the publication of the New Regulations marks a major milestone, AIFMD II and UCITS VI implementation remains an ongoing process. Further EU‑level and domestic guidance, including on enhanced reporting requirements from 2027, supervisory engagement and market practice will continue to shape how the new frameworks operate in practice.
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.