On 5 May 2026, the Central Bank of Ireland published a revised AIF Rulebook to align with AIFMD II, which was transposed into Irish law on 1 May 2026 (read more here).
As part of this alignment, and reflecting the new harmonised EU framework for AIFs engaged in loan origination, the revised AIF Rulebook removes the prohibition on Qualifying Investor Alternative Investment Funds (QIAIFs) providing third-party guarantees.
Under the revised regime, QIAIFs may now provide third-party guarantees and security, without the need for complex “cascading security” structures that have historically characterised Irish fund finance transactions.
This change follows sustained engagement with the domestic funds industry and the Central Bank’s Consultation Paper 162, published in September 2025, which proposed targeted amendments to the AIF Rulebook to support the implementation of AIFMD II and the recommendations of the Department of Finance’s Funds Sector 2030 Final Report (see our briefings here and here). In that paper, the Central Bank acknowledged that the provision of guarantees is standard market practice in fund financing arrangements, including bridge financing and financing at portfolio company or investment vehicle level within private equity fund structures.
What does this mean?
This represents a significant and welcome development for lenders to, and sponsors of, QIAIFs, particularly in the context of fund finance and real estate finance transactions, and more broadly strengthens Ireland’s offering for private asset funds, enhancing its appeal to both investors and lenders. It also aligns the Irish regulatory position with leading fund jurisdictions in areas such as fund financing, downstream structuring and loan-origination and ensuring sponsors have sufficient flexibility to structure and operate private asset strategies consistent with international best practice.
Contact us
The William Fry team has extensive experience advising lenders and sponsors on fund finance transactions. Please reach out to David O’Shea, John Aherne, Vincent Coyne or any member of the William Fry Banking & Finance or the William Fry Asset Management & Investment Funds departments if you would like to discuss the above.
Contributed by Alma Campion and Nigel Crowe.
