The domestic capital market is on the verge of a fundamental shift: from 16 April 2026, the regulation of AIF lending steps up a level.
With the domestic transposition of the AIFMD II Directive (Section 7(2)(d) of the Collective Investment Funds Act), lending carried out on behalf of alternative investment funds becomes a standalone, licence-required activity for all fund managers (AIFMs).
Why does this affect venture capital fund managers?
Although venture capital and private equity funds have previously been able to grant loans, the new regulation now opens this avenue to all AIF types — while at the same time bringing it under uniform and stringent supervisory control.
The key changes:
🔹 Licence requirement for existing managers too: Fund managers already in operation who wish to enter into new loan agreements (including shareholder loans) in the future must also apply to the MNB for a modification of their scope of activities.
🔹 Strict conditions: Authorisation requires specific credit risk policies, a business plan, and proof of compliance with the DORA Regulation on digital resilience.
🔹 No exemption under the Credit Institutions Act: This falls under the standalone regulatory framework of the Collective Investment Funds Act. An AIFM must obtain a licence even if the fund exclusively finances its own subsidiaries — the group financing exemption under the Credit Institutions Act does not apply here.
The fate of existing portfolios:
Loans already in place as of 16 April 2026 do not require a new licence, provided the fund manager does not enter into any new loan agreements. However, if new disbursements are intended, regulatory compliance cannot be avoided.
Since the new rules will require most market participants to amend their activity licences and internal policies, the PV Partners (PVP) team is on hand to provide expert support throughout the licensing process. Feel free to reach out so you can prepare for the changes in good time!📈