Where to domicile a private fund — JPF vs Guernsey PIF vs Luxembourg SCSp-RAIF vs Irish ILP, compared

Pick a closed-ended vehicle for a professional-investor private fund — private equity, private credit, real assets — and four domiciles show up on almost every shortlist: a Jersey Private Fund (JPF), a Guernsey Qualifying Private Investment Fund (QPIF), a Luxembourg RAIF in the legal form of a special limited partnership (SCSp), and an Irish Investment Limited Partnership (ILP). The published comparisons are the problem. The one genuinely neutral matrix (AIMA's) sits behind member login, and most of the free rankings still describe the JPF as capped at 50 investors and the Guernsey PIF under its pre-2025 three-route structure — both of those facts changed in 2025. This page holds the current position side by side, on the rules in force as at the last-verified date.

One split governs everything below. Jersey and Guernsey run a manager-regulated, product-light model: the fund itself is barely regulated, speed and cost are the selling points, and EU access is by national private placement only. Luxembourg and Ireland run an AIFM-regulated, product-registered model: heavier service-provider load and cost, but a full AIFMD marketing passport — the right to market to professional investors across the whole EU/EEA off one authorisation — which the Channel Islands cannot yet offer. Which side of that line you want is usually the decision; the rest is detail. Note where the line stops, though: the passport ends at the EU/EEA border, so into the UK all four vehicles market on identical private-placement terms — see UK access before you let the passport price the decision.

The master matrix

The one-line read: Jersey and Guernsey sell speed, low cost and a near-invisible product regime but only get you into the EU by private placement; Luxembourg and Ireland cost more and carry a full service-provider stack, but hand you the AIFMD passport. The JPF and the QPIF are now so close on the numbers that the choice between the two islands turns on adviser relationships and the 2026 Guernsey fee cut, not on the regime.

Jersey Private Fund — the 50-cap is gone (and check which version you're reading)

This is the single fact most stale comparisons get wrong. The Jersey Private Fund Guide took effect on 6 August 2025 and has since been revised once, on 13 April 2026 — that April revision is the current text. The mechanism matters more than the headline: the Collective Investment Funds (Jersey Private Fund) (Jersey) Order 2025 replaced the CIF Law's "restricted circle of persons" test — which required that the offer reach no more than 50 persons — with a "restricted group of investors" test containing no number at all. The new test asks only that the offer be addressed to an identifiable category of persons to whom it is directly communicated, and that only those persons may accept. Top-ups and transfers between investors are treated as part of the original offer.

Worth knowing before you chase the newest PDF: the 13 April 2026 revision changed almost nothing of substance. Comparing the two published versions clause by clause, it is overwhelmingly punctuation, hyphenation and cross-reference tidy-up, plus two small real edits — the securitisation/SPV carve-out in Part B was simplified (the July 2025 text made it conditional on either holding a Registry consent and meeting all the other Article 2 requirements of the Restriction Order, or needing no CoBO consent at all; the current text simply excludes any scheme meeting all the requirements of Article 2), and the JFSC's "sound business practice policy" was renamed the "sound business policy". So a 2025-dated matrix citing the July 2025 guide is not wrong on the structuring points — it is citing a superseded document, which is a different and lesser problem than being out of date on the law.

The trap that is expensive: the cap removal is not automatic for existing funds, and it is not an amendment. Part J of the Guide is explicit — an existing JPF must hold a new relevant consent dated on or after 6 August 2025 to rely on the JPF Order. Until it is reissued, the old consent "will continue to have conditions on the number of offers/investors" and remains subject to the 50-person test. A JPF authorised in July 2025 that wants a 51st investor needs a fresh consent, not a variation of the one it holds.

Sitting underneath all of that is a change no comparison carries: the instrument the JPF hangs off is itself being repealed in stages. The Control of Borrowing (Jersey) Order 1958 was amended by the Control of Borrowing (Jersey) Amendment Order 2026 (R&O.19/2026), in force 13 April 2026 — the same day the JPF Guide was revised. Phase one narrows the consent net rather than the fund regime. Consent falls away for unit trusts, and for non-Jersey entities raising money, holding a Jersey bank account or registering in Jersey, unless the entity is an investment fund; a new "retail investor" definition (Article A1) narrows offer and prospectus consent to retail offers; and the "relevant consent" precondition is stripped out of the Professional Investor Regulated Scheme and Special Purpose Investment Business exemptions, which broadens both as alternatives to a fund (Mourant's walk-through). Consents granted before 13 April 2026 over the now-descoped categories simply cease to have effect from that date, without invalidating anything done in reliance on them.

Investment funds are expressly kept in. Article 14(6) defines an investment fund to include a collective investment fund under the 1988 Law and a scheme that would be one but for its units not being offered to the public — which is a JPF, precisely. So a JPF still needs a CoBO consent today, and nothing in phase one touches the Part J reconsent point above. What belongs in a 2026 structuring decision is the direction of travel: the JFSC's notice of 10 March 2026 states that the wider repeal of the Control of Borrowing framework will proceed in phases and will not be completed until 2027, with further guidance during 2026. Two more phases are expected. So the JPF's regulatory hook is scheduled to be replaced — which matters most to exactly the population Part J already catches: a legacy JPF weighing whether to reconsent now is reconsenting under a regime with a published end date.

What the successor regime looks like is already on the public record, and most commentary misses it because it sits in a Government consultation rather than a JFSC one. The consultation paper Repeal of the control of borrowing framework (July 2025, closed 30 September 2025) gives its section 9 to "JPF and legacy funds", and the problem it names is exactly the one a structurer would ask about: on repeal a JPF's consent becomes void and the JPF Guide "would cease to have a statutory anchor to the COB Framework", leaving JPFs "not formally recognised" and outside the regulatory perimeter (9.3.3–9.3.4). The proposed fix is a new class of financial services business under the Financial Services (Jersey) Law 1998 — working name "private fund services business" (PFSB) — carrying a code of practice issued under Article 19 of that Law that would "place the existing JPF Guide on a clear regulatory footing" (9.1.6), with the DSP classes (V, U, X, ZG, and any FSB or TCB class for a 15-or-fewer JPF) written into the definition of the services caught (9.5.11).

The Government's feedback paper of November 2025 then hardened the intent without settling the mechanism. Industry rejected a bare notification regime — "most respondents stressed that a simple notification to the JFSC would be insufficient and that some form of regulatory approval or 'badge' should be retained" (2.7.1) — and three routes were still live at that point: the PFSB class under the FSL, amending the CIF Law to bring JPFs inside it, or a standalone private funds law (2.7.2). What Government did commit to is the part that decides whether this affects a fund being formed today: it will "ensure that transitional provisions are enacted to migrate existing COBO Consents and Conditions seamlessly into the new framework, avoiding disruption to established structures" (2.7.8.2), that DSP obligations "will continue to anchor regulatory oversight" (2.7.8.4), and that implementation guidance will give firms lead time (2.7.8.5). The consultation's own drafting note is that existing JPFs holding a consent should be "deemed to have notified and been authorised by the JFSC under the regime and are therefore considered compliant from the date of the COB Framework's repeal" (9.5.13), with all consent holders retaining good standing "with no action required on their part" (2.1.9).

So the honest reading is narrower than "unknown". The JPF product is not at risk and no re-grant is intended — but the instrument your consent sits under, the name of the permission and the code your DSP works to are all still in drafting, with commencement dates "to be set once transitional guidance is finalised" and a phased implementation envisaged (2.13.6). Two consequences worth pricing now: fund documents that recite the CoBO consent by name will need updating at some point in the fund's life, and the JPF Order's own cross-reference to the CoBO framework is itself flagged for review and amendment "to ensure alignment with the final legislative reforms" (2.12.5). See To verify.

Eligibility still bites, though — "unlimited" is not "retail". Every investor must either subscribe for at least £250,000 or meet the "professional investor" definition, which the August 2025 changes widened to expressly include a UK FCA professional client under the Conduct of Business Sourcebook and a US accredited investor under Rule 501 of Regulation D. The full professional-investor definition sits in Annex A, paragraph 1 of the current guide and runs to exactly fifteen limbs, (a) to (o) — among them persons whose ordinary business is acquiring or managing investments (limb a), individuals with net worth above US$1m excluding their principal residence and any rights under a contract of insurance (limb b), entities with US$1m or more available for investment (limb c), a "financially sophisticated employee, director, partner, expert consultant or shareholder" of a relevant service provider who takes their interest as remuneration or incentive (limbs e and f), carried-interest and co-investment arrangements (limb g), and governments and public authorities (limb j). Note the wording on the service-provider limbs: the test is financial sophistication and it expressly reaches partners and outside expert consultants, not merely senior staff — a broader gate than the "senior employee" formulation still carried by older summaries. The last limb is the one worth remembering in a hard case: limb (o) lets the JFSC admit, on application, "such other natural or legal persons as we may deem appropriate on a case-by-case basis". So the JPF opened up to more eligible investors, not to the general public — and if you are relying on a single limb for a specific investor, read that limb in the guide itself, not a summary. One useful drafting point: investor eligibility is fixed at the time of admittance and survives a later status change, so a departing employee-investor does not have to be redeemed out; and on an involuntary transfer (death, bankruptcy) the transferee need not qualify through the same limb as the transferor, but must still be a professional or eligible investor in its own right (Annex A, para 3.d).

The counting rule is where Jersey and Guernsey genuinely part company, and it is the point most "the islands have converged" summaries miss. Jersey does not look through. Part F, paragraph 7 of the Guide lets a professional investor — a discretionary investment manager, typically — acquire an interest "directly for or on behalf of one or more retail investors", and says that investor "will be treated as one investor in the relevant JPF and it will not be necessary to look through to the number of underlying investors". The JPF may rely on the intermediary's representation of its own status. That is the opposite of the Guernsey position set out below, and it is what makes a JPF workable behind a platform or a nominee. The price is a suitability duty pushed onto the intermediary: under Annex A, paragraph 5 the professional investor "must be satisfied that such investment is suitable for the underlying investor, and that the underlying investors are able to bear the economic consequences", including total loss. Note how this squares with the no-retail rule — part D.4 bars retail investors "directly or indirectly", except where Annex A paragraph 3 or 5 applies, so paragraph 5 is the express gateway for indirect retail participation, not a loophole in it. Alongside it, several holders simply do not count: carry and co-investment vehicles (F.5), a general partner that is not committing co-investment capital (F.6), and interests carrying only management or control rights with no share of profits (F.4). Feeder funds are expressly contemplated where the feeder's own investors are all professional or eligible (F.8).

What a JPF does not need is the interesting part: no depositary, no auditor, no prospectus, no promoter approval, no personal questionnaires, and no compliance with the Code of Practice for Certified Funds. What it does need is a Designated Service Provider — an existing Jersey full-substance entity, not a managed entity, registered for fund services business class V (Administrator), U (Manager), X (Investment Manager) or ZG (Trustee). The DSP carries the regime: it declares the JPF Form "complete, true and accurate", checks eligibility on a continuing basis, files the Notice of Change or Event within 28 calendar days, and files the annual JPF Return by 31 July for the period to 30 June. There is a lighter door for a "very private" JPF — 15 or fewer offers and investors — where the DSP may hold any class of FSB or TCB registration. Two further obligations sit outside the classic checklist: a JPF may be listed, but only with an officer of the JFSC's prior approval, and only for a technical listing or private placement with no active trading; and where a JPF is marketed on the basis of investing in sustainable investments, Part L requires disclosure of taxonomy alignment, the proportion of sustainable investments, the diligence and benchmarking basis, and the limits of the methodology and data.

Authorisation is a 24-hour streamlined process on a complete JPF Form plus fee, and the Guide is careful to note that this clock is separate from Companies Registry incorporation and from any AIFMD filing. Regulator fees are modest — an application fee of £1,895 and an annual fee of £1,512 under the 2026 JFSC Fees Notice (effective 1 January – 31 December 2026), with a separate £2,250 registration fee where the JPF is also an AIF. The annual fee falls due on 1 January and is pro-rated by twelfths for consents issued mid-year. Those are the 2026 figures, and the JFSC has a fee consultation for 2027 open — see To verify before a multi-year fee line goes into a model. EU/EEA distribution is by NPPR only; there is no passport.

The gotcha sits in Part C, and it is written as an expectation rather than a rule: the JFSC expects a JPF to have its governing body and management and control in Jersey, and at least one Jersey-resident director on the board of the fund or its governing body. A JPF established offshore with an offshore board is permitted — but it triggers a post-authorisation request for additional data "to establish the indirect but relevant nexus to Jersey". Cheap to satisfy at formation, awkward to retrofit. Instrument-level detail on our Jersey Private Fund regime page.

Guernsey Qualifying PIF — rebuilt in 2025, and now cheaper

Guernsey rewrote its regime in the Private Investment Fund Rules and Guidance, 2025, in force 19 May 2025 and revoking the 2021 Rules outright. Existing registrations carry over automatically: former Route 1 and Route 2 funds are treated as QPIFs, former Route 3 funds as Family PIFs. The old three-route structure collapsed into two: the Qualifying PIF (QPIF) — which merges the former Licensed-Manager and Qualifying-Private-Investor routes — and the largely-unchanged Family PIF for family members and eligible employees.

The QPIF is open only to Qualifying Private Investors — professional, experienced, knowledgeable-employee, high-net-worth, UK/EU professional client, US accredited, or a licensee-admitted investor whom the manager or administrator judges able to evaluate and bear the risk. The 2025 Rules did three commercially significant things: removed the limits on the number of investors and offers — under the revoked Private Investment Fund Rules and Guidance (2), 2021 (in force 1 November 2021) a Route 1 licensed-manager PIF was capped at 50 legal or natural persons holding an ultimate economic interest, with a rolling limit of 30 new ultimate investors in the preceding twelve months (Sch 1, Route 1(a)–(b)), and a Route 2 QPI fund at 50 such holders and no more than 200 offers of units for subscription, sale or exchange (Sch 1, Route 2(b)–(c)); the Route 3 family fund carried no numeric cap, which is why the Family PIF survived the rewrite largely unchanged — made the Guernsey-licensed manager optional — the guidance to rule 3.3 says plainly that "a PIF may, but is not required to, appoint a licensee as manager", where that was the defining Route 1 obligation; and confirmed that neither information particulars (rule 3.5(1)) nor an audit (rule 3.4 guidance) are required. If an auditor is appointed, it must operate from a place of business in the Bailiwick (rule 3.4(1)). Approval stays at 1 business day under the GFSC's fast-track PIF regime — "the Commission will declare the scheme registered in one business day following the receipt of a full PIF application", with an incomplete file simply not starting the clock.

What did not get dropped is the administrator. The PIF Rules 2025 state flatly that "Every PIF must have a designated administrator" (rule 3.1(1)); every application must identify it, the GFSC confirms its designation alongside the registration declaration, and it carries the ongoing regulatory load — annual notifications, annual reports and accounts, and quarterly statistical returns to the Commission (rules 5.2–5.4). The administrator must be Guernsey-licensed: the Commission's own position is that "all Guernsey domiciled funds must be authorised by, or registered with, the Commission, and all must be administered by a Guernsey-licensed administrator". A licensed manager, by contrast, is expressly optional. The regulated substance sits with the administrator, not the manager — and note the quarterly statistical return (rule 5.4), an ongoing obligation most comparisons omit entirely.

A second administrator-borne return was re-cut this month and belongs on the same list. The Financial Crime Returns Rules, 2026, made and in operation on 17 July 2026 under section 52 of the Protection of Investors Law, require that "designated administrators of authorised or registered collective investment schemes, licensed under the PoI Law, must file an Investment Vehicles Multi Return… covering every scheme they provide designated administrator services to" (rule 2.3(1)). A QPIF is registered by declaration under section 8 of that Law (PIF Rules 2025, rule 2.3(1)), which is exactly the class the return is defined against — so every QPIF is reported in it. The reporting period is 1 July to 30 June and the deadline 31 October following (rule 2.3(3)–(4)). The Commission's completion guidance, re-issued 1 July 2026, confirms the return replaces the former "Financial Crime Risk – Intermediary Annual Return" (Form 152), that data is required down to cell, sub-fund, share-class and basket-constituent level, and that it "is within scope of penalties for late and inaccurate submissions". The obligation sits on the administrator, not on the fund — but the data comes from the fund's investor register, so it lands in the same administration fee either way. The Commission's own note of the amendment is that it reflects "the change in name, content, reporting period, and submission deadline of Form 152" and nothing else — so a Guernsey operating calendar built before this month has the wrong name and the wrong date against it.

Two QPI categories have no direct equivalent in the other three regimes and are worth reading in full. The individual Professional Investor route requires an initial investment of not less than US$100,000 and that the amount represent no more than 25% of the individual's investable assets — a suitability test bolted onto a monetary threshold, which neither Jersey's £250,000 nor Luxembourg's €100,000 imposes. The Licensee Admitted Investor lets a licensed manager or the designated administrator vouch for an investor who fits no other category, having made "careful and appropriate enquiries" that the investor can evaluate the risks and bear a total loss. That is a discretionary admission gate delegated to a private firm, which is why Schedule 1 criteria (d) and (e) require a standing declaration to the Commission before it can be used at all.

Look-through is the operational catch. Schedule 1 Part A(a) applies to "all investors who have an ultimate economic interest in the fund", and the guidance confirms it looks through intermediate investors — except where the investment comes from a legal entity or arrangement not formed specifically to invest in the QPIF and itself managed or advised by a QPI (a collective scheme or occupational pension scheme, say), which is then treated as the investor in its own right. Carry and co-investment vehicles are not treated as investors at all. This is the one dimension on which the two islands have not converged: Jersey expressly declines to look through an intermediating professional investor (Part F, para 7), Guernsey starts from ultimate economic interest and carves back. If your distribution runs through a platform, a nominee or a discretionary manager, that difference decides which regime counts your investors — and it is invisible in a fee comparison.

Guernsey is also the only one of the four that prescribes the investor acknowledgment wording. Schedule 1 Part A(f) sets out a form of words every investor must sign — confirming they fall within the QPI definition, that retail-grade protections do not apply, and specifically that they understand there is no regulatory requirement for the fund or its financial statements to be audited and none for information particulars to be prepared. The designated administrator must retain those acknowledgments and produce them to the Commission on request (criterion (g)). Budget subscription-document time for it; it is not optional boilerplate.

The Family PIF route (Part B of the same Rules) has three registration criteria: all investors must "share a family relationship, or be an eligible employee of the family"; the PIF "cannot be marketed outside the family group"; and the designated administrator must declare to the Commission that effective procedures ensure all investors are related as family. An "eligible employee" is defined as an employee of the family who also meets the Qualifying Private Investor definition — so staff can invest alongside the family, but only QPI-grade staff.

Then the fee cut. For 2025 the GFSC PIF application fee was £4,795 (open-ended) / £4,790 (closed-ended) with a £4,235 annual fee — materially dearer than Jersey. From 1 January 2026 the GFSC reduced the PIF application fee to £1,500 and the annual fee to £1,000 under the Financial Services Commission (Fees and Administrative Penalties) Regulations, 2025 (GFSC investment fees). That undercuts the JPF's headline fees and neutralises what had been Jersey's clearest price advantage. Like Jersey, the QPIF reaches EU/EEA investors by NPPR only — no passport — and needs no depositary. Rule-level detail on our PIF Rules 2025 page.

Luxembourg RAIF (SCSp) — no product regulator, because the AIFM is the regulator

The RAIF Law of 23 July 2016 is Luxembourg's answer to the Channel Islands' speed pitch: the fund is not authorised or supervised by the CSSF at product level, so there is no product-approval bottleneck. Article 39 makes the bargain explicit on the page — the offering document must carry a clearly visible cover-page statement that the fund "is not subject to supervision by a Luxembourg supervisory authority". The trade-off is structural: Article 4 requires an authorised external AIFM, so a RAIF cannot be self-managed, and cannot rely on the sub-threshold AIFMD exemption. What Article 4 does not require is a Luxembourg one: the text accepts an AIFM authorised under Chapter 2 of the Luxembourg AIFM Law or one established in another member state within the meaning of AIFMD, so a sponsor that already runs an Irish, French or German AIFM can use it for a RAIF instead of standing up a Luxembourg manager. That materially changes the "full local stack" comparison against Ireland — the depositary, administration and audit must be Luxembourg, the AIFM need not be — see our sub-threshold AIFM comparison for where that exemption does still work. The AIFM is the regulatory anchor: it carries the full AIFMD discipline (portfolio and risk management, valuation, depositary oversight, delegation, conflicts, reporting), which is exactly what justifies the absence of CSSF product review and unlocks the full AIFMD marketing passport to professional investors across the EU/EEA.

In private equity, credit and real assets the dominant form is the RAIF constituted as an SCSp — a special limited partnership, common-law-like in feel, tax-transparent, no legal personality, contractually flexible via the LPA (a RAIF can also take corporate SICAV/SICAF or common-fund FCP form; the SCSp is the partnership route sponsors reach for). Article 23 expressly permits a SICAV-RAIF to take that form.

The well-informed investor test in Article 2 has moved and most comparisons have not caught up: the monetary threshold is €100,000, reduced from €125,000 by the Law of 21 July 2023. The alternative is a written assessment by a credit institution, investment firm, management company or authorised AIFM certifying the investor's expertise, experience and knowledge. Directors and other persons involved in the management sit outside the test entirely (Art 2(2)).

Where the cost sits is the depositary and the audit. Article 5 requires a Luxembourg depositary — registered office or branch, credit institution or investment firm — with a carve-out worth real money: a fund with no redemption rights for five years from initial investment, which does not generally hold custody assets and generally invests to acquire control of non-listed companies, may instead use a professional depositary of assets other than financial instruments (PDAoFI) under Article 26-1 of the 1993 banking law. For a classic closed-ended PE SCSp that materially changes the depositary quote. Article 43 makes the réviseur d'entreprises agréé mandatory, with no equivalent of the Jersey or Guernsey opt-out.

One constraint the island regimes do not have: minimum size. Net assets — or subscribed capital plus share premium, or the value of partnership interests — must reach €1,250,000 within 24 months of constitution (Article 32(1) for a Chapter 4 RAIF, Article 25 for a SICAV-RAIF; the period was extended from twelve months by the Law of 21 July 2023). Fall below two-thirds of that minimum and the directors or managers must put dissolution to the investors. For a fund that raises slowly, or a first-time manager warehousing a single asset, that clock is a real gate — and neither a JPF nor a QPIF nor an ILP has an equivalent.

The second constraint no fee table shows: a RAIF must spread its risks. Article 1(1)(b) defines a RAIF as an undertaking whose sole object is collective investment in assets "with the aim of spreading the investment risks" — a product-level condition of the vehicle, not a disclosure item, and one that none of the other three regimes imposes. The law puts no number on it, and the number everyone used has just been withdrawn. Circular CSSF 25/901, in force 19 December 2025, repealed Circular 07/309 (pt 51) — the 2007 text that fixed the familiar 30% single-issuer limit for specialised investment funds, and which market practice read across to RAIFs because the RAIF Law carries the same risk-spreading wording. The replacement grid is expressed by investor type: 25% of assets or commitments in one and the same entity or person, one and the same fund or investment vehicle, or one and the same other asset where the fund can be marketed to unsophisticated retail investors (pt 8(a)), raised to 50% where it is reserved to well-informed or professional investors (pt 11) — which is every RAIF — and 70% for a single infrastructure investment.

Read that grid with its carve-outs, because they are what make the number liveable and no comparison we can find carries them. The single-entity limit does not apply to securities issued or guaranteed by an OECD member state, its regional or local authorities, or by EU, regional or global supranational institutions and bodies (pt 8(a)(i)) — a treasury or bridge sleeve is not a concentration problem. The limit on one target fund or investment vehicle falls away entirely where comparable or stricter risk-spreading is ensured at the target's own level, per its sales document or the law applying to it (pt 8(a)(ii)) — which is what lets a RAIF be built as a feeder or a fund-of-funds without breaching on day one. Pulling the other way, assets "whose economic viability is closely linked to the point that these assets form a single economic entity" are not distinct assets (pt 8(a)(iii)): one building, one project, one line. Two further limits sit inside the same point and are missing from every private-funds summary — a short position in securities of one entity may not exceed the same percentage (pt 8(b)), and derivatives must deliver comparable spreading through their underlying assets, with counterparty risk that is neither centrally cleared nor collateralised limited by reference to the counterparty's quality and qualification (pt 8(c)).

Three further mechanics matter at the structuring table. Where a fund invests through intermediary vehicles, the limits bite on the investments made through them, not the vehicles themselves (pt 10) — a holdco chain does not launder concentration. Each compartment of a target fund or securitisation undertaking counts as a distinct entity where segregation of liabilities holds (pt 9). And the CSSF may grant further derogations on a duly motivated justification, or impose additional restrictions where the investment policy warrants it (pt 12).

The relief that actually decides most private-fund cases is the one the circular puts in its own chapter, and it is the reason a concentrated early portfolio is usually a drafting question rather than a breach. The limits need not apply at all during ramp-up. The sales document may provide for periods during which the investment limits do not yet apply or no longer apply (pt 14). Where the fund makes private investments — "which generally require more time to negotiate" — the ramp-up period may run up to four years from launch, against twelve months for a fund whose main purpose is UCITS-eligible assets, extendable in exceptional circumstances by in principle one further year (pt 15). A wind-down period may switch the limits off at the other end where the fund makes private investments (pt 16). The condition throughout is that the fund must not be exposed to excessive risks or conflicts of interest "that had not been previously identified", with idle cash invested as the sales document provides (pt 17). For a closed-ended PE, credit or infrastructure RAIF drawing down across a four-year investment period, that covers most of the fund's investing life — but only if the ramp-up is written into the offering document at launch. Retrofitting it is the expensive version.

Note the scope: 25/901 specifies the concept for the SIF Law and the UCI Law and does not mention the RAIF Law at all, so its application to a RAIF is read-across, not rule — see To verify. And the read-across is asymmetric: several of the circular's flexibilities are drafted as things justified to and accepted by the CSSF — a different calculation basis (pt 7), a derogation from the limits (pt 12), a ramp-up beyond four years (pt 15). A RAIF has no product authorisation and so no channel through which that acceptance could be given. The reliefs a RAIF can practically rely on are the ones that operate by drafting in the sales document; the ones that need a regulator's yes are, on their face, unavailable to it. For a genuinely concentrated strategy the clean answer remains the Article 48 risk-capital RAIF, which is exempt from risk spreading altogether.

Timing is a formation clock, not an authorisation queue: constitution recorded in a notarial deed within 5 working days (Art 34(1)), an RESA notice within 15 (34(2)), and inscription on the list held by the register of commerce and companies within 20 (34(3)) — with later changes notified within 20 working days (34(3a)). There is no CSSF product-authorisation fee, because there is no authorisation.

"Not authorised" is not the same as "not on the CSSF's books", and the step that catches first-time sponsors is on the manager's side of the wall. Circular CSSF 25/894, dated 27 June 2025 and in force with immediate effect (repealing Circular 15/612), requires every Luxembourg investment fund manager — ManCo15, registered AIFM or authorised AIFM — to complete a form for "every investment fund non-authorised by the CSSF that they undertake to manage", filed through the relevant eDesk procedure (s.4). A RAIF is squarely inside the definition: a "non-authorised AIF established in Luxembourg" means an AIF "which has not been granted prior authorisation by and/or is not subject to the prudential supervision of the CSSF" (s.1.4), and where the fund has compartments the obligation applies at the level of each new compartment. The clock is 10 working days from the point the IFM starts managing the fund (s.5) — and the circular fixes that point at the earlier of the signature or effective date of the management agreement, "it being understood that this fund may not yet have been launched", and the date of establishment where the IFM is also the managing general partner or shares an initiator with the fund. Substantial changes to what was filed go in "without delay", and the IFM has a further 10 working days to report the end of its mandate. So the RAIF's speed advantage is real, but it is not a paperwork-free launch: the filing simply sits with the AIFM rather than with the fund, which is the same place the rest of the RAIF's regulation lives. The annual subscription tax is 0.01% of net assets (Art 46(1)), and the exemption worth knowing if you are running a feeder or a fund-of-funds is Art 46(2)(a): the value of assets represented by units held in other undertakings for collective investment is exempt where those units have already borne the subscription tax under the RAIF Law, Article 174 of the 2010 UCI Law or Article 68 of the SIF Law — so a Luxembourg master-feeder chain is not taxed twice. The Law of 21 July 2023 attached a condition to it: the holding fund must state that value separately in the periodic statements it files with the Registration Duties, Estates and VAT Authority. Miss the separate line and you have not claimed the exemption. A risk-capital RAIF under Article 48 sits outside it altogether where the constitutive documents state that its exclusive object is investment in risk capital — and, usefully for concentrated strategies, such a fund is not required to spread investment risks, by express derogation from Article 1. The price is an annual auditor's report to the Inland Revenue certifying compliance with the risk-capital policy. The real cost lives in the AIFM, depositary, admin and audit line items, not the regulator's invoice.

The gotcha is the two-month replacement clock. If the AIFM resigns, is removed, loses its authorisation or becomes insolvent and is not replaced within two months, the directors must within three months ask the District Court to dissolve and liquidate the fund (Art 4(3)). The identical mechanic applies to the depositary (Art 5(5)). A RAIF cannot idle without its service providers — worth a succession line in the LPA. Article-by-article detail on our RAIF Law page.

On AIFMD II, Luxembourg has transposed: the law of 3 March 2026 (published in the Official Journal on 9 March 2026) carries Directive (EU) 2024/927 — delegation, liquidity-management tools, depositary rules and the new loan-origination framework (leverage capped at 175% of NAV for open-ended and 300% for closed-ended loan-originating AIFs) — into the AIFM Law, effective from the EU-wide 16 April 2026 deadline; the new supervisory-reporting obligations apply from 16 April 2027. A RAIF's AIFM carries all of it, so check your AIFM's implementation state, not just the fund documents.

Irish ILP (QIAIF) — a common-law LP with the passport, freshly re-based for AIFMD II

The Investment Limited Partnership is Ireland's common-law partnership vehicle, modernised by the ILP (Amendment) Act 2020 to compete directly with the Cayman and Channel Islands LP for private-markets money. An ILP is authorised by the Central Bank as a QIAIF (Qualifying Investor AIF) — a regulated product carrying a €100,000 minimum subscription and the qualifying-investor test (MiFID professional client, appraised-expertise investor, or self-certified informed investor; knowledgeable persons involved in managing the fund are exempt from both). Authorisation is fast for a regulated product: the QIAIF 24-hour fast-track means an application filed with the AIFM's and depositary's certifications by 5pm on the business day before the proposed authorisation date is authorised the next business day, with the letter issuing by close of business — provided the parties are already Central Bank-approved. The Rulebook also formally recognises a capital commitment, drawn down in stages as the fund ramps, as a way of meeting the €100,000 minimum — closing a gap against private-equity practice that Jersey and Guernsey never had. One further relaxation sits outside the Rulebook, in standing Central Bank guidance: where the QIAIF is an umbrella, "the aggregate of an investor's investments in the sub-funds… can be taken into account" in meeting the €100,000 floor (Subscriptions into Qualifying Investor AIFs, last revised 3 July 2013). An investor spreading €100,000 across four sub-funds of one umbrella qualifies; the same investor spreading it across four standalone funds does not.

Two nuances in the AIFM row are worth having before you compare service-provider load. First, a QIAIF authorised by the Central Bank must have an authorised AIFM within two years of launch — the date the initial offer period closes, or the first closing where there are several (Rulebook ch.2, s.2(i)(1)) — but read the opening words of that rule before you plan a runway around it. The two years apply "unless it is required by the AIFM Regulations to have an authorised AIFM at an earlier date", so they are available only while the manager stays below the AIFMD threshold; cross it and authorisation falls due when the Regulations say, not on the fund's second birthday. Subject to that, it can start life under a registered (sub-threshold) AIFM, which is not true of a Luxembourg RAIF, where Article 4 demands an authorised external AIFM from constitution. Second, the ILP Act's own conditions are more specific than "an Irish depositary": section 5(1)(c) requires "a depositary being a person maintaining a place of business in the State", section 12(1) requires a registered office and a principal place of business in the State, and section 8 makes the Central Bank's authorisation conditional on the general partner either being AIFMD-authorised or satisfying the Bank as to competence and probity. There is no minimum capital in the Act.

What that on-ramp does not do is defer the rest of the stack, and this is the part every matrix that sells Ireland's two-year runway as a light-touch start leaves out. Parts III and IV of Chapter 2 set out what a QIAIF carries while its manager is still a registered (sub-threshold) AIFM or a non-EU AIFM, and the load is substantial. The registered AIFM must still appoint a single depositary under Regulation 22(1) of the AIFM Regulations (Part III, para 3) — so the Irish depositary is a day-one cost whether or not the manager is authorised, where a JPF or a QPIF under a sub-threshold manager has no depositary at all. On top of that it must comply with named provisions of the AIFM Regulations — general principles (reg 13(1)(f)), delegation (reg 21(1)(f)), liquidity management (reg 18(3)), valuation (reg 20(1)–(7) and the first sentence of reg 20(15)), the transparency obligations in regs 23 and 24 bar a handful of carve-outs, and the loan-origination rules (regs 16(6)(d), 16(6A), 16(6B) and 17A) — plus a fifteen-article slice of AIFMD Level 2 running from counterparty and prime-broker due diligence (Art 20) and inducements (Art 24) through the valuation articles (Arts 67–74) to the annual-report content rules (Arts 103–106). One structural condition sits inside it: a QIAIF that is a loan-originating AIF must be closed-ended while it has a registered AIFM (Part III, para 2). Part IV imposes the same set, article for article, on a QIAIF with a non-EU AIFM — the shape a US or Channel Islands manager reaches for. Read together, the runway defers the AIFM authorisation and the passport; it does not defer the depositary, the valuation discipline or the reporting.

That closed-ended condition has a mirror image on the authorised-AIFM side, and it is the clarification a private-credit sponsor most needs before picking Ireland. AIFMD II's default is that a loan-originating AIF must be closed-ended unless the AIFM can demonstrate to its home regulator that the fund's liquidity risk management system is compatible with its investment strategy and redemption policy (Article 16(2a), inserted by Directive (EU) 2024/927) — and what was unclear in Ireland was whether taking that route would cost the QIAIF its fast-track. It does not. The Central Bank has confirmed that a QIAIF managed by an Irish authorised AIFM, or by an authorised AIFM in another member state, may be authorised as an open-ended loan-originating AIF through the standard 24-hour process, and that it will not require a pre-submission on the fund's adherence to the ESMA regulatory technical standards; where a Retail Investor AIF takes the same form, the Bank will engage with the AIFM on those proposals first (Arthur Cox, 5 August 2026 — a secondary record; see To verify). It is consistent with the Central Bank's own pre-submission page, which names Irish property assets, digital-asset exposure and open-ended ELTIFs with limited liquidity as the pre-submission categories and does not name loan origination at all. Read with the paragraph above, the split is clean: authorised AIFM — open-ended loan-originating QIAIF, 24 hours, no pre-submission; registered AIFM — closed-ended only (Part III, para 2). Whether an Irish credit fund can be evergreen turns on the manager's permission, not on the fund's terms.

Reporting is lighter than most matrices claim. The QIAIF must publish an audited annual report and file it with the Central Bank within six months of the financial period end — but the half-yearly report obligation applies only to QIAIFs established as unit trusts or common contractual funds (ch.2, s.5(i)(3)). An ILP files annually. Note also the first-accounts rule: a set of accounts must be prepared to a reporting date within twelve months of the first issuance of units, and the first annual report to a date within eighteen months of establishment.

As a QIAIF it takes the full stack — authorised AIFM, Irish depositary, Irish-based administration, auditor — and in return gets the full AIFMD passport. The current wrinkle is timing, and it has two layers. The substantive re-base was the revised AIF Rulebook published on 5 May 2026 (feedback statement to CP162), aligned with the AIFMD II transposition and applying with immediate effect. On top of that, the Central Bank reissued the Rulebook again on 29 July 2026 — the PDF at the Central Bank's standing Rulebook link is now headed AIF Rulebook, July 2026, and the Bank's AIF guidance page records that it "published the latest version of the AIF Rulebook" on that date. The Central Bank publishes no blackline and no note of what the July edition moved, so if you are working from a copy downloaded between May and July, re-download it. Every Irish statement on this page has been checked against the July 2026 text. Two changes from the May re-base matter for private funds: (1) the legacy loan-origination chapter was removed, folding Irish loan-originating funds into the EU-wide AIFMD II loan-origination framework — see our Ireland vs Luxembourg loan-origination comparison — and (2) the restriction on QIAIFs giving third-party guarantees was removed, which simplifies subscription-line and asset-level financing across fund families (Arthur Cox on the revised Rulebook). The Rulebook sits on top of the Irish AIFMD II transposition itself — S.I. No. 181 of 2026, the European Union (Alternative Investment Fund Managers) (Amendment) Regulations 2026, in operation from 1 May 2026 (Arthur Cox on the Irish implementation). If you are structuring an Irish private credit or fund-finance vehicle right now, structure to the current (July 2026) Rulebook, not the pre-AIFMD-II version still described in most older guides.

A third change is easy to miss and matters to anyone comparing service-provider load. The depositary chapter is materially wider than its predecessor: it now expressly covers depositaries of AIFs with authorised AIFMs, of Professional Investor Funds with registered AIFMs, and of QIAIFs with registered and non-EU AIFMs. Ireland's analogue to the Luxembourg PDAoFI — the depositary of assets other than financial instruments (DAoFI) — is now formalised: an applicant must be "a company incorporated in Ireland which is authorised as an investment business firm under the Investment Intermediaries Act 1995" (ch.5, s.viii(1)(a)), and must additionally satisfy the Central Bank on its capacity to meet safekeeping and oversight obligations. Where such a fund does hold financial instruments, the Bank expects custody of them to be delegated; a DAoFI that does not delegate must either put a qualifying guarantee in place or hold sufficient financial resources.

The change most likely to move a private-equity decision is what the Rulebook stopped restricting at portfolio level, and it is missing from every matrix we can find. Read against the July 2026 text, the QIAIF general restrictions (ch.2, s.1(i)) run to ten paragraphs and contain no diversification limit and no significant-influence rule. The prohibition on a fund acquiring "shares carrying voting rights which would enable it to exercise significant influence over the management of an issuing body" now appears exactly once in the Rulebook, in Chapter 1, which governs Retail Investor AIFs (s.1(i)(1)). For a control-oriented buyout or activist strategy that removes a product-level rule Ireland used to carry and the Channel Islands never did. The prescriptive subsidiary regime went the same way: a QIAIF may now invest through "intermediary investment vehicles, including but not limited to special purpose vehicles, aggregators, subsidiaries or on a co-investment basis" on five principles-based conditions — prospectus disclosure of their use and purpose, a constitutional restriction on any wholly owned subsidiary that is not under the QIAIF's control as AIFMD defines it, the vehicle not itself being an investment fund, AIFM due diligence before investing, and documented oversight policies (ch.2, s.1(vii)). The old conditions — prior Central Bank approval for each subsidiary, the fund's own directors forming a majority of the subsidiary board, and a bar on the subsidiary appointing third parties or entering contracts unless the fund was a party — survive only for Retail Investor AIFs (ch.1, s.1(xi)). One restriction does remain, and it is worth reading before a fund-finance structure is drawn: a QIAIF "shall not raise capital from the public through the issue of debt instruments", though private issuance to a lending institution or other debt provider to facilitate financing arrangements is expressly permitted where the prospectus sets out the detail (ch.2, s.1(i)(5)). Investment limits, where a QIAIF sets its own in the prospectus, are tested at the time of purchase; a passive breach must be recorded and remedied as a priority objective rather than treated as a hard trip-wire (ch.2, s.1(i)(10)).

On regulator cost, the Central Bank charges no application fee to authorise a fund — the product-level cost is the annual industry-funding levy, set each year by regulations under section 32D of the Central Bank Act 1942 and recovering the previous year's regulation costs. Authorised ILPs sit in Category E1 (Investment Funds), where the Funding Strategy and Guide to the 2026 Industry Funding Regulations sets a minimum levy of €8,952 for a standalone fund or single-sub-fund umbrella, plus €593 per sub-fund (including the first) for umbrellas with more than one sub-fund. Those figures bite from 20 July 2026, the day the 2026 Regulations (S.I. No. 348 of 2026) were signed and came into operation (s.2.3).

Two things moved with that edition, and the second matters more than the first. The headline figures rose by about 2.5%, from €8,734 and €579. More consequentially, the fifty-sub-fund cap was removed — footnote 6 to Table 8 records that the previous maximum contribution for umbrella funds "has now been removed". Where the 2025 Guide held an umbrella's levy to €37,684 however many sub-funds it ran, the levy now rises without limit at €593 a sub-fund: an eighty-compartment umbrella pays €56,392 rather than the €37,684 it would have been capped at. For a single-strategy ILP the change is a rounding error; for a platform umbrella it removes the ceiling that made each additional sub-fund nearly free at the margin, and it is worth re-running against your compartment plan rather than a prior year's invoice. Either way this is still an order of magnitude above the Channel Islands' regulator fees, before any AIFM, depositary or administrator invoice arrives.

EU access — the one thing the islands cannot sell

A Luxembourg RAIF and an Irish QIAIF, managed by an authorised EU AIFM, market across the EU on a passport: one notification, every member state. A JPF and a Guernsey PIF are non-EU AIFs and reach EU investors only through the national private placement regime under AIFMD Article 42 — registered country by country, on each member state's own terms, with each state free to add requirements.

Two facts decide whether that gap matters. First, Article 42 does not import the depositary obligation in Article 21: NPPR marketing pulls in the transparency requirements (annual report, disclosure to investors, reporting to regulators) and the non-listed-company provisions, not the full directive. That is precisely why the islands can offer a depositary-free private fund that is still marketable into Europe — the depositary saving survives EU distribution. Second, the passport has never been extended to third countries: Article 67 makes the extension contingent on a Commission delegated act following an ESMA opinion, and that act has never been adopted. ESMA's positive advice on Jersey and Guernsey dates from 2016 and has gone nowhere since, and AIFMD II left Article 67 untouched. The position is stable, not pending — plan on NPPR permanently rather than provisionally, and treat any comparison that describes island passporting as "anticipated" with suspicion.

The islands' own filing steps are asymmetric and easy to trip over. In Jersey, the Alternative Investment Funds (Jersey) Regulations 2012 require JFSC approval of the AIF before any marketing into the UK or an EU/EEA state, and the JFSC is explicit that this "is in addition to" whatever the destination state requires; note too that the AIF Code of Practice was split into separate EU/EEA and UK versions with effect from 16 April 2026, so a manager marketing into both now works to two codes. In Guernsey, the AIFMD (Marketing) Rules 2021 run the other way — you market under the member state's own rules and notify the Commission within 14 calendar days of commencing, and the detailed Article 42 reporting goes to the EEA member state's regulator, not to the GFSC. Jersey gates the front door; Guernsey audits the back one.

AIFMD II changes the jurisdictional gate on NPPR, and it is two tests, not one. The old condition — that the third country not be listed by the FATF as a non-cooperative country or territory — is deleted and replaced by a requirement that the country where the non-EU AIFM and the non-EU AIF are established is not identified as a high-risk third country under Article 9(2) of the anti-money-laundering directive and is not named in Annex I of the EU list of non-cooperative jurisdictions for tax purposes, alongside an OECD-Article-26-standard tax information exchange agreement with each marketing member state (Directive (EU) 2024/927, amending AIFMD Articles 36(1) and 42(1)). Both islands clear both tests today: the Council's Annex I, last revised on 17 February 2026, lists American Samoa, Anguilla, Guam, Palau, Panama, Russia, the Turks and Caicos Islands, the US Virgin Islands, Vanuatu and Viet Nam — neither Jersey nor Guernsey appears, and neither is an AML high-risk third country. The point is not that the islands are at risk; it is that an island's NPPR access is now hostage to two EU lists that are re-cut on a schedule — the tax list twice a year, next in October 2026 — where before it turned on an FATF listing that has been dormant for years. Member states had until 16 April 2026 to transpose, so the NPPR terms a manager registered under in 2024 are not necessarily the terms applying to a new registration now. Our AIFMD II implementation tracker holds the member-state-by-member-state position.

UK access — the door all four use

Comparisons of these four vehicles argue about the EU passport and then stop, which would be fine if the money were all in Frankfurt. For a manager whose LPs are London institutions, family offices and pension schemes, the operative question is the UK — and there the four domiciles are level. The passport ends at the EU/EEA border, and the FCA treats an EEA manager as a third country AIFM: its national private placement regime page states that "references to 'third country' includes a country that's in the EEA". So a Luxembourg RAIF or an Irish ILP formed today reaches UK professional investors through the same UK national private placement regime as a JPF or a QPIF.

Three regulations of the Alternative Investment Fund Managers Regulations 2013 carry it, and which one you are in depends on the manager, not the fund: regulation 57 where a full-scope UK or Gibraltar AIFM markets a non-UK AIF — the common shape for a London manager running a Jersey or Guernsey fund; regulation 58 where a small third country AIFM markets any AIF; and regulation 59 where an above-threshold third country AIFM does, which is where an EU AIFM with a RAIF or an ILP lands. There is no approval step and no waiting period — FUND 10.5 says the AIFM "is entitled to market the AIF as soon as a notification containing all of the required information has been sent to the FCA". Contrast Jersey's own gate, which runs the other way: the JFSC must approve the AIF before any marketing into the UK, and since 16 April 2026 does so under a UK-specific version of the AIF Code.

The conditions sit in the regulation, and this is where the UK and the EU have just parted company. Regulation 59(2) requires appropriate cooperation arrangements for systemic-risk oversight between the FCA and the supervisory authorities of the countries where the AIFM and the AIF are established, and that the country "is not listed as a Non-Cooperative Country and Territory by the Financial Action Task Force". That is the test AIFMD II deleted on the EU side and replaced, from 16 April 2026, with the two-list gate set out above. So a Jersey or Guernsey fund marketing on both sides of the Channel now faces two differently drafted third-country tests — the EU's, re-cut on a published schedule, and the UK's, still written against a FATF designation. Both islands clear both today; the point is that the two gates no longer move together. See To verify on how the FATF limb is applied in practice.

The ongoing load is real but sits on the manager. An above-threshold third country AIFM marketing under regulation 59 must comply with FUND 3.2 (investor information), FUND 3.3 (annual report of the AIF) and FUND 3.4 (reporting to the FCA); a small third country AIFM under regulation 58 supplies the instruments it trades and its principal exposures and concentrations under SUP 16.18. The fees are small and — usefully for a comparison — identical whichever of the four domiciles you picked: a notification fee of £280 per AIF (FEES 3 Annex 1AR, pricing category 1) and an annual periodic fee per AIF of £411 for a regulation 57 or 59 notification and £287 for regulation 58 (FEES 4 Annex 4R). The FCA invoices the first period in the month following a notification, and annually from July thereafter.

What is moving is the UK regime around that door. On 14 July 2026 HM Treasury published a draft Alternative Investment Fund Managers Regulations 2026 with a policy note, alongside the FCA's CP26/28, which would move most firm-facing requirements into FCA rules and re-tier UK AIFMs as small, medium or large. For an overseas fund the headline is continuity: the policy note states that the instrument "makes minimal changes to the National Private Placement Regime (NPPR) for UK and third country AIFMs marketing certain AIFs in the UK, a position which received broad support at consultation". The change worth diarising is enforcement-side — a "simplified process for the FCA to suspend and revoke permission to market under certain grounds". Technical comments on the draft instrument close 14 October 2026; HM Treasury expects to lay the legislation in early 2027, and the requirements "will come into force at the same time as the replacement FCA rules", which fixes no date.

The practical read: if the raise is UK-led, the passport is not part of the decision. You would be paying the Luxembourg or Irish AIFM, depositary, administration and audit stack for EU access you may not use, while a JPF or QPIF reaches the same investors through the same FCA notification at the same £280. The passport earns its cost on a genuinely pan-European raise. Where the LP base is UK plus a handful of EU states, price NPPR in both directions first — it is usually cheaper than the stack.

Which one, when

This is analysis, not advice — the right answer depends on your investor base, distribution plan and existing relationships, and none of it substitutes for structuring counsel. But the decision tree a structurer actually walks is short:

• Do you need to actively market across the EU/EEA? If yes, and you want one authorisation that reaches every member state, you are choosing between Luxembourg RAIF-SCSp and Irish ILP — the passport is the whole reason to take on the heavier, dearer AIFM/depositary/admin stack. The Channel Islands cannot passport.
• Is the raise UK-led? Then the passport is not the tiebreak, because it does not reach the UK. All four market to UK professional investors through the same FCA private-placement notification — regulation 59 for an EU AIFM with a RAIF or an ILP, exactly as for a Jersey or Guernsey fund — at the same £280 notification fee and £411 a year. On a UK-heavy raise the Luxembourg and Irish stacks are bought for optionality, not access; make that an explicit decision rather than a default.
• Luxembourg vs Ireland once you're on the passport side: Luxembourg wins on ecosystem depth, brand recognition with continental LPs, and vehicle range; Ireland wins if you want a common-law limited partnership in an English-speaking, common-law jurisdiction, favour a QIAIF's fast-track certainty, or are building private credit / fund-finance structures that benefit from the May-2026 Rulebook's loan-origination alignment and the removal of the third-party-guarantee restriction — and, if the product is to be evergreen rather than drawdown, from the Central Bank's confirmation that an open-ended loan-originating QIAIF under an authorised AIFM keeps the 24-hour authorisation with no pre-submission. Two structural tiebreaks the brochures skip: Ireland lets you launch under a registered AIFM and upgrade within two years, where Luxembourg needs an authorised AIFM from day one; and Luxembourg imposes a €1.25m minimum within 24 months that Ireland does not. If the plan is a multi-compartment platform rather than a single fund, price the Irish levy on the compartment count you actually expect: the fifty-sub-fund cap came off on 20 July 2026, so Ireland's product-level cost now scales linearly with sub-funds where it used to plateau, while Luxembourg's subscription tax scales with assets instead. For a first-time manager with an uncertain first close, both point the same way. Price the runway accurately, though: it is worth less than it reads. The two years run only while the manager stays below the AIFMD threshold, and Part III of Chapter 2 still requires a single depositary under Regulation 22(1) plus the valuation, liquidity and transparency provisions while the AIFM is merely registered — so what you defer is the AIFM authorisation and the passport, not the Irish service-provider bill. Cutting the other way, if you already run an authorised EU AIFM, Luxembourg's Article 4 lets you use it — the AIFM does not have to be Luxembourg-established — so the incremental local build for a RAIF is depositary, administration and audit, not a manager. Familiarity and administrator footprint usually decide the rest.
• Is the strategy concentrated, or control-oriented? This is the tiebreak the fee tables hide, and it now runs the opposite way to the folklore. A Luxembourg RAIF must spread its risks as a condition of the vehicle (Art 1(1)(b)) — read through Circular 25/901 at 50% in one entity and 70% in one infrastructure asset for a well-informed-investor fund, and applied to the investments held through your SPVs rather than to the SPVs — unless it is constituted as an Article 48 risk-capital RAIF, which is exempt but must confine itself to risk capital and file an annual auditor's certificate to that effect. Before reaching for Article 48, price the two softer routes in the same circular: the ramp-up period of up to four years for a private-investment strategy, during which the limits simply do not apply (pt 15), and the carve-outs for OECD-sovereign paper and for target funds already subject to comparable risk-spreading (pt 8(a)). Both work by drafting, and both have to be in the offering document at launch — which is the practical reason this belongs in the domicile decision rather than in year three. An Irish QIAIF has no diversification rule at all and, since the 2026 Rulebook, no restriction on taking shares that give it significant influence over a portfolio company. A JPF and a QPIF have no portfolio rules of any kind. So a three-asset fund, or a buyout fund taking board control, faces a live drafting question in Luxembourg and none in the other three.
• Is your investor base largely non-EU, or reachable by private placement into a handful of EU states? Then the passport is dead weight, and you should be looking at Jersey (JPF) or Guernsey (QPIF) for speed (24h / 1 business day), a near-invisible product regime, no depositary and no audit. NPPR covers the EU states that matter for most manager-led raises.
• Jersey vs Guernsey is now a close-run thing. On the numbers they have converged: both dropped their investor caps in 2025, both dropped the mandatory local-manager requirement (Guernsey in 2025; Jersey never had a licensed-manager mandate — it uses the DSP administrator), neither requires a depositary. Guernsey's 2026 fee cut (£1,500 / £1,000) now undercuts Jersey's 2026 fees (£1,895 / £1,512), so price is no longer the tiebreak it once was — though the gap is a few hundred pounds a year, which is noise next to an administrator's invoice. Where they genuinely differ: Jersey's entry ticket for a non-professional is £250,000 against Guernsey's US$100,000 capped at 25% of investable assets; Guernsey adds a quarterly statistical return and a prescribed investor acknowledgment; Jersey adds an annual JPF Return and a Jersey-resident-director expectation. One asymmetry has nothing to do with the fund regime: Jersey is midway through repealing the Control of Borrowing framework the JPF consent is granted under — phase one landed 13 April 2026 and kept investment funds in scope, and the JFSC puts completion in 2027. The successor permission is still in drafting, with a new class of financial services business under the Financial Services (Jersey) Law 1998 the leading candidate; Government has committed to migrating existing consents without any action by the holder, so this is a change of statutory basis rather than a risk to the product. Guernsey's registration basis (section 8 of the Protection of Investors Law) is not moving. That is not a reason to avoid Jersey, but it is a reason to expect a consent-mechanics change mid-life. The choice usually falls to where your administrator and directors already sit.
• Single-family or club money? A Guernsey Family PIF is the lightest-touch registered route; a JPF works equally well for a small club deal, and a "very private" JPF of 15 or fewer offers relaxes even the DSP's registration class. Neither needs the Luxembourg/Ireland machinery. But test the prior question first, because Jersey's answer to a pure family arrangement is not a fund at all: under Annex B of the JPF Guide, an arrangement between persons connected by a "family connection" or an "employment connection" will not be treated by the JFSC as a JPF, provided it falls outside the CIF Law definition of a collective investment fund, its administration is carried out by a Jersey FSB/TCB-registered person that is not a managed entity, and it is disclosed in the CoBO consent application. The definitions are drawn wide — "relative" reaches aunts, uncles, first cousins, nieces and nephews, and a "family vehicle" holding for those people counts as connected. Where it fits, that is cheaper than any of the four regimes compared here, because it is none of them.

The practical gotcha: do not let a stale comparison make the decision for you. The two most-cited "facts" against the Channel Islands — the JPF's 50-investor cap and the Guernsey PIF's old multi-route, licensed-manager, audited regime — are both obsolete as of 2025, and Guernsey's fee disadvantage flipped on 1 January 2026. If an adviser's matrix still shows either, it predates the current rules; check the version before you rely on it. That is the entire reason this page carries a Last verified date.