Domestic

CBI updates the AIFMD Q&A

On 7 March 2025, the Central Bank of Ireland updated its AIFMD Q&A. The revised edition clarifies issues around a QIAIF acting as guarantor for a third party, the definition of ‘financial institution’ in the AIF Rulebook and on QIAIF loan origination.

European

Delays for ESMA work on AIFMD II, UCITS Eligible Assets and MiFID II

On 3 March 2025, the European Securities and Markets Authority (ESMA) published a letter to the European Commission with details of a number of its 2025 deliverables which are being deprioritised and postponed. This will free up resources for ESMA’s highest priority workstreams. The full list of deprioritised or postponed deliverables are set out in the annex to ESMA’s letter.

Deprioritised workstreams (with rescheduled delivery dates) include:

• AIFMD II: RTS on open ended loan originating alternative investment funds (initial deadline was 16 April 2025; delayed by six months)
• AIFMD II: Guidelines to specify the circumstances in which the name is unfair, unclear or misleading (initial deadline was 16 April 2025; delayed by at least 12 months)
• UCITS Eligible Assets Directive: Technical advice on eligible assets (original deadline was October 2024, delayed to April 2025; now delayed by a further three months)
• MiFID II/MiFIR review: RTS on CTP incidents statistics reporting (initial deadline was 1 September 2025; delayed by three months)
• MiFID II/MiFIR review: RTS on order execution policies (initial deadline was 29 December 2024; delayed by six months)

European Commission outlines its strategy for the Savings and investments union

On 19 March 2025, the European Commission adopted its strategy for the savings and investments union (SIU), with the objective of improving the way the EU financial system channels EU citizens’ savings to productive investments. It seeks to offer EU citizens broader access to capital markets and better financing options for companies. The European Commission’s proposed policy measures are grouped under the headings:

• citizens and savings
• investments and financing
• integration and scale
• efficient supervision in the single market

The SIU also aims at enhancing the integration and competitiveness of the EU banking sector.

The European Commission’s proposed policy measures of relevance to the investment funds and asset management sector include:

• adoption of measures (legislative or non-legislative) by Q3 2025 to create a European blueprint for savings and investments accounts or products based on existing best practice
• by Q4 2025 measures to stimulate equity investments by institutional investors
• by Q3 2026, a review and upgrade of the EuVECA Regulation, including by widening the scope of investable assets and strategies
• in Q4 2025 propose legislation to remove remaining barriers to the distribution of EU-authorised funds across the EU and propose measures to reduce operational barriers affecting cross border groups
• a potential review of the Shareholders Rights Directive by Q4 2026 to make it easier for investors, intermediaries and issuers to operate across Member States
• European supervisory authorities and national competent authorities to make full use of currently available supervisory convergence tools and implement the simplification agenda
• in Q4 2025 measures to strengthen supervisory convergence tools and make them more effective
• proposals in Q4 2025 to achieve more unified supervision of capital markets as indicated in the competitiveness compass, including by transferring certain tasks to the EU level

In Q2 2027, the European Commission will publish a mid-term review of the overall progress in achieving the SIU.

For more information on these topics please contact any member of A&L Goodbody's Asset Management & Investment Funds team.

This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.