Ireland Private Market Funds: Ireland Solidifies its Credentials 

Having just transposed the second iteration of the Alternative Investment Fund Managers Directive (AIFMD) into law, Ireland’s reputation as a leading fund domicile for private market funds continues to grow.

JTC takes a closer look at why the Irish funds industry is in such impeccable shape.

AIFMD 2 Ireland: What Fund Managers Need to Know

On May 1, AIFMD 2’s implementation in Ireland was confirmed after the enabling Statutory Instruments required for transposition were signed by the Tánaiste.

Although not as far-reaching as the original AIFMD – a landmark piece of regulation introduced following the 2008 Financial Crisis – AIFMD 2 is still going to be impactful, especially for private market fund managers of loan origination funds in Ireland and across the EU.

Notable reforms under AIFMD 2 include:

• The introduction of a 300% leverage cap for closed ended funds, falling to 175% for open-ended funds
• A default requirement that loan origination funds should be designated as closed-ended vehicles unless they can demonstrate that their liquidity risk management profiles are compatible with those of an open-ended product
• A baked-in 5% risk retention requirement of the notional value of the loans which managers originate and sell
• Concentration limits on the exposures managers can have to single borrowers
• A ban on “originate to distribute” strategies

Managers must now have clearly defined loan origination policies and procedures.¹

While AIFMD 2 will require loan origination managers to make some structural changes, the good news is that Ireland is not gold-plating the rules.

“AIFMD 2 is bringing a degree of harmonisation to what was previously a fragmented industry subject to local rules and local market idiosyncrasies. By standardising the regulations for loan origination funds, it should become easier for firms to manage their cross-border operations in the EU,” said Lloyd Collier, Senior Director – UK and Ireland, JTC.

The Central Bank of Ireland (CBI) also published revisions to its AIF Guidebook. Not only do these updates align domestic AIF/AIFM requirements with AIFMD 2, but they introduce a number of flexible measures for private market funds,² including permitting Qualifying Investor Alternative Investment Funds (QIAIFs) with non-EU AIFMs to engage in loan origination, letting open-ended QIAIFs benefit from the structuring flexibility previously only available to closed-ended QIAIFs and allowing QIAIFs to guarantee the liabilities of certain third-party obligations.³

Why Ireland is a Premier Fund Domicile for Global Managers

Ireland is well-positioned to attract greater private market fund domiciliation share in a post-AIFMD 2 world.

A common law jurisdiction where English is the primary spoken language gives Ireland a competitive edge, particularly with North American managers looking to avail themselves of the AIFMD pan-EU marketing passport.

Ireland’s attractive tax regime is also looked upon favourably by private market fund managers. Along with its existing double taxation treaty with the US, Ireland is making a number of positive changes to its tax framework. The authorities have pledged to strengthen the holding company regime and simplify the rules around special purpose vehicle taxes and withholding taxes.

The abundance of fund structures is another compelling draw for General Partners (GPs).

“Ireland has excellent fund structuring options relative to other leading domiciles. The country has several highly-regarded fund structures, including the Irish Collective Asset Management Vehicle (ICAV), the Investment Limited Partnership (ILP) and the unregulated 1907 LP, all of which are AIFMD-compliant,” said Collier.

ICAVs and ILPs have plenty of strategic benefits – they are highly flexible, offer speed to market, provide generous tax treatment and are subject to prudential regulation and robust governance oversight. Meanwhile, the 1907 LP structure is becoming increasingly popular among smaller and start-up managers, as it is exempt from CBI registration, which helps keep costs under control.

The Service Provider Advantage for Ireland Private Market Funds

Service provider depth and expertise in Ireland are second to none.

Take the country’s burgeoning legal sector, for instance.

“Irish law firms are unique insofar as the lawyers typically only focus on Irish common law, giving them a depth of understanding and knowledge that is unparalleled. These law firms also have boots on the ground. In contrast to other fund hubs where the lawyers advise out of, say London or New York, Ireland’s lawyers are almost always based in Ireland. This gives them extraordinary access to key decision-makers and regulators,” said Collier.

JTC is well-entrenched in Ireland’s private market funds ecosystem, offering private market clients a wide range of global solutions, strong governance, disciplined risk management and technology enabled services.

Core to JTC’s product suite are its Escrow and Sustainability Services.

Fully licensed under the EU’s Payment Services Directive 2 (PSD2), JTC Escrow and Payment Services B.V. acts as an independent escrow agent, supporting GPs with everything from M&A/real estate transactions, investor/LP commitments, litigation and arbitration awards, milestone-based transactions, including project funding and special purpose acquisition companies (SPACs).

“A robust escrow solution is a critical enabler if M&A transactions and other private market deals are to happen frictionlessly in today’s turbulent markets – and this is something, which leading providers such as JTC can facilitate,” said Collier.

Meanwhile, JTC’s Sustainability Services team helps private market fund managers navigate the fast-evolving Environment, Social, Governance (ESG) regulatory environment. It does this by developing and preparing clients’ ESG policies, providing dedicated ESG training and supporting firms with ESG reporting.

“Access to high-calibre service providers can make a huge difference for managers, given the complexities involved with running private market funds nowadays,” continued Collier.

¹ Deloitte – May 13, 2025 – Navigating the new frontier: Understanding the impact of AIFMD 2 on EU alternative investment managers

² McCann Fitzgerald – May 7, 2026 – AIFMD 2: Strengthening Ireland’s competitive edge

³ Dillon Eustace – May 6, 2026 – Central Bank of Ireland amends its AIF Rulebook

Lloyd Collier will be speaking at the Irish Funds Frankfurt Seminar 2026 on May 12 on a panel titled “Why Ireland? The Strategic Choice for Global Asset Managers”.