Why Managers are Focused on the ELTIF and Ireland as its Home

The New European Long-Term Investment Fund Framework (ELTIF) has unlocked a EUR 10bn, and rapidly scaling, European private-markets channel. Domicile is now the decisive lever for speed, cost and reach.

The Bottom Line

Ireland delivers ELTIF to market in 24 hours, taxes the fund at zero, passports it into 27 EU markets and services it in the EU’s deepest English-speaking ecosystem, while Solvency II’s 22% capital charge (1 January 2026) opens an insurer wallet measured in trillions.

The Window is Open and Competitors are Already Moving

Morningstar’s State of ELTIFs 2026 report1 confirms the inflection: 189 new ELTIFs and 72 new authorisations since January 2024; circa EUR 10bn in evergreen AUM and accelerating. From 1 January 2026, Solvency II cuts the capital charge on ELTIF holdings from 39% to 22% and removes look-through, re-pricing the product for every EU insurer. First movers with EU-passported, retail-ready vehicles capture the flows. Domicile choice determines who they are.

Authorised in 24 Hours. No Domestic Gold Plating.

Clean AIF rulebook

The Central Bank of Ireland authorises ELTIFs directly under EU Regulation 2015/760. Domestic RIAIF and QIAIF overlays, subsidiary rules, loan-origination restrictions, private-equity carve-outs, do not apply.

24-hour fast track

Qualifying Investor and Professional Investor ELTIFs are authorised in 24 hours, one of the fastest authorisation timelines in the EU. Retail ELTIFs follow a streamlined process under Chapter 6 of the AIF Rulebook.

Every legal structure, one platform

The ICAV, ILP, PLC, unit trust or CCF, single fund or umbrella with multiple sub-funds, is available to house an ELTIF. The ICAV is the cross-border institutional standard; the ILP delivers Delaware and English-LP-aligned terms that US and UK LPs  are familiar with.

AIFMD II, already done

Ireland has retired its bespoke loan-origination regime in favour of the EU-harmonised model (175% leverage open-ended; 300% closed-ended) and replaces prescriptive wholly-owned-subsidiary rules with a disclose-and-oversee framework. SPV stacks, co-investment vehicles and portfolio-level guarantees are now market-standard.

Zero Tax at the Fund Level. 

Gross roll-up

Regulated Ireland investment funds pay no Ireland tax on income or gains, no NAV tax, no subscription tax, and apply no withholding to non-resident or exempt Irish investors. Returns typically reach LPs intact.

Treaty reach and US check-the-box

Ireland has over 75 double-tax treaties, among the widest in the EU, accessible to the ICAV, which can elect partnership treatment for US federal tax purposes. A single structure serves US, EU and Asian capital efficiently.

One Licence. 27 EU Markets. Retail and Professional.

True pan-EU distribution

The Ireland ELTIF carries the full EU marketing passport into all 27 Member States, to retail and professional investors alike. Adjustments to the ELTIF law has removed the facilities-agent requirement and the gold-plated retail suitability tests - Morningstar reports 29% of evergreen ELTIFs are still trapped in a single market; an Ireland vehicle is not one of them.

Aligned with the US and the UK, frictionless

English-language documentation, common-law contracts and ILP terms aligned to Delaware/English market practice eliminate friction with US and UK LPs, side-letter counterparties and financing banks.

Insurer demand, unlocked

Solvency II revisions effective from 1 January 2026 cut the capital charge on ELTIF holdings to 22% (compared to 39% for comparable illiquid AIFs) and waive look-through. As a result, Ireland ICAVs and ILPs sit at the centre of the insurer-ready ELTIF universe.

The EU's Deepest Servicing Engine - At Scale.

Scale

Ireland is the second-largest fund jurisdiction in Europe and services a material share of Luxembourg-domiciled funds, proof that operational primacy is independent of where the wrapper sits.

Semi-liquid, battle-tested

Gates, notice periods, swing pricing and side pockets, the ELTIF liquidity toolkit, are everyday practice for Ireland administrators across QIAIF and UCITS books. This is critical expertise after the first major ELTIF gating event recorded by Morningstar in late 2025.

Plug-and-play distribution

Full connectivity with Allfunds, Clearstream, Euroclear and every global custodian means there can be wealth-platform distribution at scale, on day one.

Why Ireland? At a Glance.

For more information or advice on the implications of the ELTIF or any other aspect of Ireland's ELTIF competitiveness, please contact David Naughton (Partner and Head of our Investment Funds and Financial Services Regulation department), or Doireann O'Daly, Partner.


¹Morningstar. 'The State of ELTIFs 2026'. Available online: https://www.morningstar.com/en-gb/business/insights/research/european-long-term-investment-funds