Welcome to the November 2025 edition of our Asset Management & Investment Funds Update.
In this month’s edition we look at:
- Key Dates & Deadlines: Q4 2025
Stay ahead of upcoming deadlines and key dates with our legal & regulatory tracker. - Central Bank of Ireland 2025 year-end application cut-off times
The Central Bank of Ireland (CBI) has published the cut-off times that will apply in relation to fund and fund service provider submissions that are to take effect before the end of December 2025. Normal timeframes apply until 22 December 2025 for QIAIFs / professional and qualified ELTIFs seeking authorisation/ approval - SFDR 2.0
As has been widely reported, a “leaked” draft of the European Commission’s (EC) SFDR 2.0 long awaited proposal went into circulation on 6 November 2025. The official proposal is not scheduled to be released by the EC until 19 November and so the contents of the leaked draft should be treated with caution until the official position is released. - AIFMD II document updates: Central Bank of Ireland introduces streamlined filing process
The CBI has introduced a streamlined filing process for post-authorisation updates to fund documentation for Alternative Investment Funds (AIFs) and Undertakings for Collective Investment in Transferable Securities (UCITS). - Central Bank of Ireland sustainability risks and disclosures CSA Feedback report
The CBI released its feedback report on 23 October 2025 on the ESMA common supervisory action on sustainability risks and disclosures (CSA). Overall, the CBI findings are broadly in line with regulatory expectations. However, there are areas that require a marked improvement, particularly relating to ongoing monitoring processes and the quality of certain SFDR disclosures. - New ESA SFDR Q&A on PAI disclosure
A new SFDR Q&A released by the ESAs for financial market participants relating to entity-level PAI statements. - Loan originating AIFs: ESMA publishes rules
ESMA published its regulatory technical standards (RTS) on open-ended loan originating AIFs on 21 October 2025. The RTS determine the liquidity and related requirements with which loan originating Alternative Investment Funds must comply to maintain an open-ended structure. - European Commission de-prioritises Level 2 acts
The EC announced that it will not adopt 115 “non-essential” Level 2 acts in financial services legislation before 1 October 2027, as part of its simplification agenda and the broader Savings and Investments Union strategy. These acts were identified as not critical to the functioning of their corresponding Level 1 legislation and often imposed disproportionate compliance burdens or lacked urgency. - EU Benchmarks Regulation: simplification from 1 January 2026
Amendments to the EU Benchmarks Regulation (BMR) to limit the scope of the BMR to “critical” or “significant” benchmarks or certain climate-related or commodity benchmarks will become effective on 1 January 2026. All other benchmarks will be “non-significant” benchmarks. - Irish Government budget for 2026: investment fund implications
Amendments The Irish Minister for Finance presented the government’s budget for 2026 on 7 October. A number of provisions are of relevance for funds. - Funds Sector 2030 Implementation Plan
The Funds Sector 2030 Implementation Plan was published by Ireland’s Department of Finance on 7 October 2025. The Implementation Plan operationalises the strategic recommendations from the Funds Sector 2030 Review, aiming to future-proof Ireland’s investment funds industry and maintain its global competitiveness. - European Commission post on UCITS Eligible Assets
The European Commission (EC) released an article on UCITS called “UCITS at 40 – what’s next for eligible assets?”. We can expect more consultation on UCITS eligible assets from the EC in 2026.
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