AIFMD II: The Pan-European Private Credit Passport

 The April 2026 transposition deadline for AIFMD II has officially created a harmonized "Loan Origination Passport" for the European Union. For private credit managers in Luxembourg and Ireland, the patchwork of national lending restrictions has been replaced by a single EEA framework. This allows funds to lend directly to SMEs across all 27 member states, significantly broadening the addressable market for non-bank finance.


Technically, AIFMD II introduces strict "Risk Retention" rules: managers must retain 5% of the notional value of each originated loan to align incentives with investors. Additionally, the directive imposes leverage caps—175% for open-ended funds and 300% for closed-ended funds—calculated using the commitment method. For US managers entering the European market, the 2026 strategy involves launching "Semi-Liquid" ELTIF 2.0 structures that utilize the AIFMD II passport. These funds allow for monthly or quarterly redemptions, provided the manager maintains a 15-25% "liquidity sleeve" in UCITS-compliant assets.

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