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Introduction
On 29 January 2026, the Central Bank of Ireland (the "Central Bank") published a note detailing the new authorisation-extension process for alternative investment fund managers ("AIFMs") engaging or seeking to engage in loan origination through their alternative investment funds ("AIFs") under management, (here). The note provides detail as to how such AIFMs can engage with the Central Bank in order to extend their existing authorisations in advance of the national implementation of Directive 2024/927/EU ("AIFMD II") by 16 April 2026.
Scope and Requirements
The new loan origination rules under AIFMD II apply to all AIFs that originate loans and their respective AIFMs, with additional requirements applying to those AIFs which have loan origination as their principal strategy. The origination of loans on behalf of an AIF is an additional AIFM function requiring authorisation by the Central Bank and the Central Bank is requiring these AIFMs to extend their authorisation permissions in advance of 16 April 2026.
The Central Bank has stated that it will take a proportionate approach to the authorisation extension of AIFMs managing loan originating Qualifying Investor AIFs to enable such AIFMs to achieve the requisite authorisation by 16 April 2026.
Authorisation Process
The Central Bank has stated that an AIFM seeking such an authorisation extension should submit the below to the Central Bank's FSP Authorisations Team:
- a letter to the FSP Authorisations Team seeking authorisation to provide the Annex I function of originating loans on behalf of an AIF; and
- a separate letter which should:
- list the AIFs which originate loans and for which it acts and when these were established;
- outline the list of the policies and procedures it has in place to manage loan origination activity in relation to those funds;
- outline how, in its view, these policies and procedures are aligned with the requirements for AIFMs perform the function of originating loans on behalf of an AIF under AIFMD II; and
- advise whether the AIFM has experienced any issues in relation to management of such AIFs since its authorisation.
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