A U.S. Fund Sponsor’s Perspective on AIFMD 2.0

As the April 2026 implementation date for the recast Alternative Investment Fund Managers Directive (AIFMD and, as recast, AIFMD 2.0) draws closer, U.S. private fund sponsors face a targeted shift in the E.U. fund regulatory landscape that requires careful consideration and planning. Although AIFMD 2.0 amounts more to a series of targeted amendments than a complete overhaul of the existing AIFMD framework, a number of changes will be of particular importance to U.S. fund sponsors marketing into or otherwise operating in Europe.

This article focuses in detail on two specific changes introduced under AIFMD 2.0: amendments to the conditions to marketing under the National Private Placement Regime, and the introduction of a harmonised E.U. regime for direct lending (or “loan originating”) funds. In addition, this article briefly discusses other changes relevant to U.S. fund sponsors, including revisions to the delegation regime, and the expansion of the information required under the investor disclosure and regulatory reporting requirements.