We recently brought together a panel of industry specialists to examine the regulatory changes reshaping Ireland's funds framework and what they mean for asset managers operating in, or entering, the European market.
The webinar covered AIFMD II, liquidity management tools, the pan-EU loan origination regime, proposed changes to sustainability disclosure rules, and the growing role of data and technology in regulatory supervision.
The Central Bank sets the tone for 2026
Shortly before the webinar, the Central Bank of Ireland issued a Dear CEO letter outlining its supervisory priorities for the year ahead. A central theme was resilience.
Against a backdrop of geopolitical uncertainty, capital markets volatility, and rapid technological change, boards and management companies are expected to demonstrate that their operating frameworks can absorb disruption while maintaining regulatory compliance.
Ireland's position in the global funds industry remains strong. The jurisdiction services roughly 72% of European-domiciled ETFs and 41% of the world's hedge funds. The regulatory direction being set for the coming years aims to reinforce that position while strengthening governance and risk management across the sector.
AIFMD II: the April 2026 deadline
The most immediate regulatory development discussed was AIFMD II, which takes effect on April 16, 2026.
Two areas attracted particular attention during the panel discussion: liquidity management tools and the introduction of a pan-EU loan origination framework.
- Liquidity management tools
Under AIFMD II, open-ended AIFs must be able to activate suspension of dealing or side pockets and must also embed at least two additional liquidity management tools from a prescribed list. These include mechanisms such as redemption gates, swing pricing, and anti-dilution measures.
Funds must also establish documented policies governing how these tools are activated and deactivated. As a result, many managers are reviewing fund documentation and governance procedures ahead of the implementation deadline. - Pan-EU loan origination regime
AIFMD II also introduces a harmonised framework for loan-originating funds across the EU, replacing Ireland's existing L-QIAIF regime and creating a more consistent regulatory structure for private credit strategies across member states.
For Ireland, this development may strengthen its position in a market that has grown significantly over the past decade.
Acting despite regulatory ambiguity
Some aspects of AIFMD II remain open to interpretation, particularly around liquidity tool calibration and delegation oversight.
Firms are expected to interpret the framework and implement governance structures suited to their own operating models, rather than waiting for prescriptive guidance. Active engagement with regulators and experienced service providers can help demonstrate good-faith compliance even where detailed guidance has not yet been issued.
Reporting obligations are increasing
Regulatory reporting requirements are expected to expand over the coming years. Updates to the AIFMD Annex IV reporting template are expected from April 2027, introducing additional disclosures across areas such as leverage monitoring, delegation structures, and marketing jurisdictions.
During the discussion, panellists also highlighted the importance of maintaining consistent data across reporting processes, particularly where multiple providers are involved.
Sustainability disclosure reform
The webinar also examined proposed reforms to the Sustainable Finance Disclosure Regulation, often referred to as SFDR 2.0.
The proposed framework introduces an EU product labelling structure intended to clarify how sustainability characteristics are presented to investors. While implementation is expected around 2028, managers launching new products today must still comply with the current disclosure regime.
Transparency remains the central objective. Investors must be able to clearly understand the sustainability characteristics of the products they are investing in.
Technology and regulatory supervision
Technology is also influencing how regulators supervise the industry.
Supervisory authorities are increasingly using data and analytical tools to review disclosures and identify inconsistencies across regulatory submissions. As these tools become more widely deployed, the accuracy and consistency of regulatory data will face greater scrutiny.
Across the industry, firms are also exploring how artificial intelligence may assist with document analysis, data aggregation, and the preparation of regulatory reports.
Watch the full discussion
This article highlights several themes from the panel discussion. The full webinar explores these topics in greater depth, including:
- How boards should respond to regulatory ambiguity under AIFMD II
- The operational implications of liquidity management tool requirements
- How managers are preparing for expanded Annex IV reporting
- What proposed SFDR reforms could mean for future product design
- How regulators are beginning to use data and technology in supervisory oversight
