ESMA publishes final RTS on open-ended loan-originating AIFs

On 21 October 2025, the European Securities and Markets Authority (ESMA) released its final report on the draft Regulatory Technical Standards (RTS) for open-ended, loan-originating Alternative Investment Funds under the revised AIFMD. The RTS set out clear conditions that such funds must meet in order to retain an open-ended structure.

The standards place particular emphasis on robust liquidity management, the maintenance of adequate liquid assets, and the regular use of stress-testing frameworks. They also define expectations for redemption arrangements that appropriately reflect the liquidity characteristics of loan-originating portfolios. In developing the final text, ESMA considered the structure of underlying loan exposures, repayment horizons, and the granularity and composition of loan books.

The report reflects feedback gathered during the public consultation, which concluded in March 2025, including input provided by ALFI and other industry stakeholders. ESMA has now submitted the finalised RTS to the European Commission. The Commission is expected to decide on their adoption within three months, with the possibility of a one-month extension.