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On 5 May 2026, the Central Bank of Ireland published its revised AIF Rulebook alongside the CP162 Feedback Statement.
The headline change from a fund financing perspective is that the long‑standing restriction preventing QIAIFs from providing third‑party guarantees has been removed.
What's changed
Since the AIF Rulebook was introduced in 2013, a QIAIF has been prohibited from acting as guarantor for any party other than itself or a wholly-owned subsidiary. In practice, this meant certain transactions - most commonly master-feeder subscription line financings, but also certain asset-level and NAV deals - required complex cascading pledge structures.
The March 2025 Q&A softened the position; CP162 has now removed it entirely, aligning the QIAIF regime with AIFMD II and the ELTIF Regulation.
Why it matters
- Subscription lines and capital call facilities within ‘fund families’ can now be granted by Irish QIAIFs directly, without engineering a cascade.
- Financing packages can be negotiated without ‘Ireland-specific’ workarounds.
- Ireland's private markets offering becomes more competitive.
What sponsors and lenders should be doing now
- Review existing QIAIF constitutional documents and prospectuses - direct guarantees will need to be properly disclosed and within the fund’s stated investment policy.
- Revisit in‑flight financings where a cascade was being built purely for Irish regulatory reasons.
- Keep cascades where other drivers apply (e.g. ERISA / commercial structuring).
Combined with the removal of the L-QIAIF chapter and the broader CP162 reforms, this is the most significant overhaul of the QIAIF regime since 2013. Ireland is now ideally positioned as a private markets fund domicile.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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