Why CP162 Matters to Private Market Funds Currently in, or Launching in, Ireland

Authored by: Andrea Lennon, Head of Client Service, Ireland
Published on: November 5, 2025

Every few years, a regulatory development arrives that changes more than just a rulebook. It reshapes how an entire market operates. For Ireland’s private capital industry, the Central Bank of Ireland’s Consultation Paper 162 (CP162) is exactly that moment.

At first glance, it looks like a routine update to the Alternative Investment Fund (AIF) Rulebook. In reality, it represents something much larger: Ireland’s bid to modernise its fund regime for the next decade and stay at the forefront of global private markets.

At Gen II, we believe understanding why CP162 matters is just as important as knowing what it says, because for fund managers, administrators and investors alike, its impact will be practical, immediate and far-reaching.

Why CP162 Matters to Private Market Managers?

For managers, CP162 is about freedom and flexibility. It introduces a capital commitment model, broader investor exemptions and greater scope to design share classes and investment structures that fit real-world needs.

That means managers can launch funds that mirror global market practice, from closed-end private equity to open-ended credit, real estate and hybrid strategies. The consultation also integrates the European Long-Term Investment Fund (ELTIF) framework, expanding opportunities to attract longer-duration capital from institutional investors.

The result is a more versatile regime, one that supports creativity in fund design without compromising investor protection. For many Gen II clients, this will translate into shorter setup times, simpler approvals and more operational alignment across jurisdictions.

For U.S. and UK fund managers, CP162 opens a clearer pathway into Europe. By extending the AIF Rulebook to non-EU AIFMs, it allows sponsors to manage or market Irish QIAIFs with greater certainty and less administrative friction.

That matters for one simple reason: access. Ireland’s familiar legal system, tax-neutral treatment, and Section 110 SPV regime make it a natural entry point to the EU. With CP162, that gateway becomes even smoother.

For cross-border strategies, particularly in private credit and hybrid funds, this combination of flexibility and regulatory assurance is a powerful draw. It means sponsors can focus on investment execution, confident that their fund structure and operations meet European expectations from day one.

What Does this Mean for Gen II Clients?

At Gen II, our clients rely on us to turn regulation into readiness. CP162 will require enhanced governance documentation, new liquidity tools and updated reporting workflows. For many firms, those changes could be complex. For our clients domiciled in Ireland, they’re already underway.

We’re reviewing fund governance frameworks, testing data architecture and aligning our operational systems to anticipate the consultation’s direction. The goal is simple: to make sure our clients are ready to benefit as soon as the new Rulebook comes into force.

It matters because early preparation is an advantage. Managers who act now, with the right administrative partner, can launch faster, report more effectively and demonstrate compliance from day one. In a market where investors prize transparency and efficiency, that readiness is a big differentiator.

The Future of Private Capital in Ireland

CP162 arrives at a time when private markets are expanding in scale, sophistication and investor scrutiny. The next generation of funds will be multi-asset, multi-jurisdictional and technology enabled. Ireland’s updated framework recognises that reality.

This is where regulation meets opportunity. Gen II’s focus is on helping clients use these reforms to build stronger, smarter operating models, ones that combine governance rigour with operational efficiency. Ultimately, CP162 matters because it modernises more than rules, it sets a higher standard for how private funds should be structured, serviced and overseen – and it’s up to administrators like us to ensure our clients can meet it confidently.

If you’re a fund manager preparing for CP162 or considering establishing a new vehicle in Ireland, get in touch with Andrea Lennon to discuss how Gen II Ireland can help you plan, structure and operate with confidence.

About Andrea Lennon

Andrea Lennon leads Gen II’s Irish business and is responsible for the strategy, growth and success of Gen II Ireland. With more than 25 years of experience in investment funds and capital markets, she has worked across the full end-to-end value chain — from establishing new entities and developing go-to-market strategies to managing client relationships and daily fund operations.

Before joining Gen II, Andrea held senior operational and client-facing roles with major financial services institutions. She holds multiple Central Bank of Ireland PCF appointments, including PCF-1 (Executive Director), PCF-2B (Non-Executive Director), PCF-8 (Chief Executive) and PCF-11 (Head of Finance).