European Long-Term Investment Fund (ELTIF)

Jurisdiction and status

ELTIF rules are in EU regulations and apply directly; they sit on top of AIFMD, because an ELTIF is an EU AIF whose manager must be an authorised EU alternative investment fund manager (AIFM).

Portfolio rules under ELTIF 2.0

Redemptions and liquidity

An ELTIF may be closed-ended or, under ELTIF 2.0 and the RTS, offer redemptions subject to a redemption policy, minimum holding period, liquidity management tools and a share of liquid assets consistent with the redemption terms. It may also match transfer requests between exiting and incoming investors. These features allow evergreen and semi-liquid ELTIFs as well as traditional closed-ended ones.

Retail distribution

ELTIF 2.0 removed the original regime's EUR 10,000 minimum investment and the cap on the share of a small retail investor's portfolio that could be invested in ELTIFs. Retail distribution remains subject to a suitability assessment under MiFID II and to the ELTIF's own disclosure requirements. ELTIFs marketed only to professional investors face fewer constraints.

How managers and investors use ELTIFs

Managers use the ELTIF to reach European wealth-management and retail channels with private equity, private credit, infrastructure and real estate strategies under one EU passport, often through feeder or semi-liquid structures. ELTIF is a regulatory product status, not a legal form: the fund itself takes a national form, such as a Luxembourg investment company with variable capital (SICAV) or special limited partnership (SCSp). The closest UK equivalent is the Long-Term Asset Fund (LTAF).

Not the same as

• Long-Term Asset Fund: The LTAF is a UK authorised open-ended fund regime for long-term assets; ELTIF is the EU product regime.
• UCITS: UCITS are liquid EU retail funds with strict diversification and eligible-asset rules; ELTIFs are AIFs designed for illiquid long-term assets.
• Reserved Alternative Investment Fund: A reserved alternative investment fund (RAIF) is a Luxembourg national fund regime; an ELTIF is an EU product authorisation that can be marketed to retail investors across the EU.

Common mistakes

• Applying the original 70% eligible-asset rule. ELTIF 2.0 requires at least 55%.
• Assuming all ELTIFs are closed-ended. ELTIF 2.0 and the RTS allow redemptions under conditions.
• Treating ELTIF as a legal form of company or partnership.
• Quoting the old EUR 10,000 retail minimum.

Edge cases

• ELTIFs authorised under the rules applicable before 10 January 2024 are deemed compliant until 11 January 2029, and without time limit if they raise no additional capital; they may opt in to the new rules by notifying their competent authority.
• An ELTIF can invest in other funds, including other ELTIFs, if those funds invest in eligible assets and have not themselves invested more than 10% of their assets in other collective investment undertakings (a condition that does not apply to feeder ELTIFs).

Questions

Sources

1. Regulation (EU) 2015/760 on European long-term investment funds (ELTIF Regulation). European Parliament and Council, Official Journal of the EU, L 123, 19.5.2015, Adopted 29 April 2015; applied from 9 December 2015. Status: In force as amended by Regulation (EU) 2023/606 (checked 2026-10-01). Regulation (EU) 2015/760, consolidated text of 2024-01-10, Arts. 5(2), 6(1)(b), 13(1)–(2), 16(1)(a)–(d), 30(1); original text Arts. 13(1), 30(3) — supports: ELTIF label for EU AIFs managed by an authorised EU AIFM; 55% eligible assets and 20% limits; borrowing limits; retail suitability; original 70% rule and EUR 10,000 / 10% retail limits
2. Regulation (EU) 2023/606 amending Regulation (EU) 2015/760 (ELTIF 2.0). European Parliament and Council, Official Journal of the EU, L 80, 20.3.2023, Adopted 15 March 2023; applies from 10 January 2024. Status: In force (checked 2026-10-01). Regulation (EU) 2023/606, Art. 1(8) (new Arts. 13(1)-(2), 16(1)), Art. 1(20) (new Art. 30), Art. 2; recital 47 — supports: 55% eligible assets; 20% limits; borrowing; retail suitability; removal of EUR 10,000 minimum and 10% cap; applies from 2024-01-10; grandfathering to 2029-01-11 and for ELTIFs raising no new capital; opt-in
3. Commission Delegated Regulation (EU) 2024/2759 supplementing Regulation (EU) 2015/760 (ELTIF RTS). European Commission, Official Journal of the EU, L series, 25.10.2024, Adopted 19 July 2024; entered into force the day after publication (26 October 2024). Status: In force (checked 2026-10-01). Delegated Regulation (EU) 2024/2759, Arts. 1, 5, 7, 10-13 — supports: Hedging-only derivatives, redemption policy and liquidity tools, matching, disposal, costs; in force 2024-10-26
4. Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD). European Parliament and Council, Official Journal of the EU, L 174, 1.7.2011, Adopted 8 June 2011; transposition by 22 July 2013. Status: In force; amended by Directive (EU) 2024/927 (AIFMD II) (checked 2026-10-01). Directive 2011/61/EU — supports: ELTIF is an EU AIF managed by an authorised AIFM
5. Directive 2014/65/EU on markets in financial instruments (MiFID II), Annex II Professional Clients. European Parliament and Council, Official Journal of the EU, L 173, 12.6.2014, Adopted 15 May 2014; applied from 3 January 2018 (as extended). Status: In force (amended) (checked 2026-10-01). MiFID II — supports: Suitability framework for retail distribution
6. FCA Handbook COLL 15: Long-term asset funds. Financial Conduct Authority, FCA, In force from 15 November 2021; amended since. Status: In force (checked 2026-10-01). COLL 15.8.12R(2) — supports: LTAF redemptions no more often than monthly, with a notice period of at least 90 days

• Alternative Investment Fund Managers Directive (AIFMD)
• Semi-Liquid Fund
• Evergreen Fund

• Open-End Fund
• Private Credit
• Sustainable Finance Disclosure Regulation (SFDR)