Positioning for Growth: Why Private Asset Managers are Turning to Ireland

With major regulatory shifts like the Alternative Investment Fund Managers Directive (AIFMD) II on the horizon and a wave of structural reforms already reshaping the market, Ireland is fast emerging as a premier destination for private asset managers seeking a strong European foothold.

As the largest hedge fund and exchange-traded fund (ETF) jurisdiction in the EU—second globally after the U.S.—Ireland’s reputation in financial services is well-established. Today, Ireland is poised to become a key EU destination for private asset management as well.

Key advantages of Ireland for private asset managers

Ireland’s growing appeal for private asset managers is rooted in a potent combination of jurisdictional strengths:

● English-speaking, common-law jurisdiction: Especially valuable for managers accustomed to U.S. and UK legal standards

● Extensive talent pool: Ireland boasts one of the largest financial services workforces in the EU, without needing to import expertise

● Tax treaty network: Vehicles like the Irish Collective Asset Management Vehicle (ICAV) offer access to Ireland’s extensive double taxation treaty network, which includes the U.S.—a critical advantage in today’s complex global trade environment

● Robust regulatory framework: Ireland’s regulator, the Central Bank of Ireland (CBI), is known for balancing investor protections with industry growth

● Depth of expertise: Ireland’s administrators, depositaries and service providers have extensive experience across asset classes, providing the infrastructure to support sophisticated private asset strategies

Recent developments in Ireland’s private assets landscape

Investment Limited Partnership regime

One critical catalyst for change has been the modernised Investment Limited Partnership (ILP) regime, introduced in 2021. This regulated common law partnership is designed to meet the needs of private equity, private credit, venture capital, infrastructure and real estate strategies. It falls within the AIFMD regime and can fully avail of the marketing passports and associated investor protection features. The ILP aligns Ireland with other global jurisdictions traditionally favoured by private asset managers.

Uniquely, an ILP can be structured as an umbrella fund with separate sub-funds, segregating liability between sub-funds and making it possible to have one general partner (GP) over multiple sub-funds. Managers can also deploy different investment strategies in each sub-fund, catering for different limited partners (LPs) and reducing servicing costs.

ELTIF 2.0

The European Long-Term Investment Fund (ELTIF) 2.0 is set to help managers raise capital from professional clients and retail investors in the 27 EU member states by removing the threshold constraints of the original ELTIF framework. Initially, retail investors had to invest a minimum of €10,000 in an ELTIF without exceeding 10% of their overall portfolio of financial instruments. This requirement no longer exists, allowing the EU to better compete with the U.S. from a retail perspective. ELTIF 2.0 also allows managers to invest in a wider range of eligible assets. Insurance companies and wealth managers are using it to help individual investors access opportunities across private equity, credit and infrastructure that were previously only available to institutional investors. Ireland, France and Luxemburg have all launched new ELTIF structures. One major benefit of the Irish ELTIF is that it can avail of the CBI’s 24-hour approval process, potentially speeding up launch timescales.

AIFMD II

Looking ahead, AIFMD II (due to take effect in April 2026) will mark a significant shift in the regulatory landscape for private credit funds in Europe. The directive aims to level the playing

field by introducing more flexibility in fund structuring, particularly for semi-regulated products. This update positions Ireland to better compete with Luxembourg’s popular SICAV structure, providing managers with a broader range of options that align with AIFMD requirements.

AIFMD II makes targeted changes to AIFMD provisions around loan origination and liquidity management, generating significant manager interest. AIFMD II also introduces a pan-European loan origination passport aimed at eliminating cross-border lending barriers. An Irish-domiciled fund could therefore lend to a French corporate, avoiding complex workarounds to avoid falling foul of French banking monopoly rules.

The harmonised loan origination rules give private credit managers more fund domicile options and facilitate implementation of the same lending strategy from any EU member state. This shift unlocks capacity across the wider European funds industry, and Ireland in particular, to underpin the predicted growth of European direct lending funds.

Whilst AIFMD II clearly marks closed-ended funds as the most appropriate structure for direct lending strategies, the new regulations will also allow direct lending through open-ended funds (subject to use of appropriate liquidity management tools). Currently, most EU member states only allow loan origination through closed-ended funds.

Funds Sector 2030

Investor allocation to private assets continue to grow as investors seek higher yields, portfolio diversification and longer-term growth opportunities amid evolving global market dynamics. This trend has been ongoing for some time with the rise in hybrid structures. Ireland’s Funds Sector 2030 review reinforces the jurisdiction’s commitment to innovation and regulatory leadership, ensuring a resilient and future-ready ecosystem for private assets.

Structural options for private assets in Ireland

Ireland offers a flexible suite of structures to meet the diverse needs of private asset managers, from large institutional funds to boutique players.

Regulated fund structures:

● ILP: A vehicle tailor-made for private equity, private credit, venture capital and infrastructure investments. ILPs are fully AIFMD-compliant and viable for both EU and non-EU investors

● ICAV: A corporate fund vehicle offering flexible governance and tax treaty benefits,

making it ideal for a range of private asset strategies

● ELTIF: A structure that enables broader retail access to long-term private asset investments. ELTIFs enjoy a fast-track authorisation process, which minimises regulatory hurdles

Unregulated structures:

● Section 110 SPVs: Popular across Europe, these vehicles provide a cost-effective, lightly regulated option for structuring securitisations, credit strategies and bespoke private asset deals, making them particularly attractive for smaller managers or niche strategies

The future of private assets in Ireland

Ireland’s deep talent pool, competitive market-ready fund structures, and robust legal and regulatory framework have created an opportunity for Ireland to become one of the world’s premier jurisdictions for private assets—and the Irish funds industry is ready for the challenge.