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.

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 (get the current version)

This is the single fact most stale comparisons get wrong. Under the amendments to the Jersey Private Fund Guide effective 6 August 2025, the JFSC removed the previous restriction that effectively limited a JPF to 50 offers/investors. New JPFs face no numeric investor cap, and the rules on top-ups and secondary transfers were relaxed so they no longer erode an investor count. Existing (pre-August-2025) JPFs can opt into the new regime by requesting an amended COBO consent.

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 some fifteen limbs — among them persons whose ordinary business is acquiring or managing investments, individuals with net worth above US$1m (excluding the main residence), entities with over US$1m of investable assets, senior employees and directors of the fund's service providers, carried-interest and co-investment participants, and governments/public authorities. 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.

Structurally the JPF stays deliberately light: a governing body, a mandatory Jersey-regulated administrator acting as Designated Service Provider (DSP) (which runs the AML/CFT and eligibility gate), no depositary and no audit requirement. The JFSC has committed to a 24-hour authorisation turnaround. Regulator fees are modest — an application fee of £1,849 and an annual fee of £1,475 per the 2025 CoBO Fees Notice. EU/EEA distribution is by NPPR only; there is no passport, though the guide anticipates JPFs would be passport-eligible if the AIFMD passport is ever extended to third countries.

Guernsey Qualifying PIF — rebuilt in 2025, and now cheaper

Guernsey rewrote its regime in the Private Investment Fund Rules and Guidance, 2025. 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 investor-number caps (previously 50 investors / 200 offers); dropped the requirement to appoint a Guernsey-licensed manager (formerly the Route 1 obligation); and removed the prospectus and audit requirements. Approval stays at 1 business day under the GFSC's fast-track PIF regime, covering both the fund and any "PIF-only" investment-management licence.

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). A licensed manager, by contrast, is expressly optional ("A PIF may, but is not required to, appoint a licensee as manager" — rule 3.3 guidance note). The regulated substance sits with the administrator, not the manager.

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 (Carey Olsen on the GFSC fee reduction). 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.

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

The RAIF (Reserved Alternative Investment Fund, under the 2016 RAIF Law) is Luxembourg's answer to the Channel Islands' speed pitch: it is not authorised or supervised by the CSSF at product level, so there is no product-approval bottleneck. The trade-off is structural — a RAIF must appoint an authorised external AIFM, cannot be self-managed, and cannot rely on the sub-threshold AIFMD exemption. 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 SICAV-RAIF as an SCSp — a special limited partnership, common-law-like in feel, tax-transparent, no legal personality, contractually flexible via the LPA. The full stack is mandatory: a Luxembourg depositary, central administration in Luxembourg, and an approved statutory auditor. Investors must be well-informed (institutional/professional, or others committing ≥ €100,000 or certified as expert). The RAIF is constituted by notarial deed (or recorded by one within five working days) and entered on a list at the Luxembourg Trade and Companies Register; realistic time-to-market is roughly 4–10 weeks assuming an AIFM is already in place. There is no CSSF product-authorisation fee (there is no authorisation), but a 0.01% annual subscription tax applies in the general regime — with the risk-capital (SICAR-equivalent) regime and qualifying ELTIF/short-term-MMF RAIFs exempt. The real cost lives in the AIFM, depositary, admin and audit line items, not the regulator's invoice.

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 is authorised the next business day — provided the AIFM and depositary are already lined up.

As a QIAIF it takes the full stack — authorised AIFM, Irish depositary, Irish administrator, auditor — and in return gets the full AIFMD passport. The current wrinkle is timing: the Central Bank published a revised AIF Rulebook on 5 May 2026 (feedback statement to CP162), aligned with the AIFMD II transposition. Two changes 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 separate page on loan-originating funds — 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 May-2026 Rulebook, not the pre-AIFMD-II version still described in most older guides.

On regulator cost, the Central Bank charges no application fee to authorise a fund — the product-level cost is the annual industry-funding levy. Authorised ILPs sit in Category E1 (Investment Funds), where the 2025 Funding Strategy and Guide sets a minimum levy of €8,734 for a standalone fund or single-sub-fund umbrella, plus €579 per sub-fund (including the first) for umbrellas with more than one sub-fund, capped at fifty sub-funds — a maximum of €37,684. That is an order of magnitude above the Channel Islands' regulator fees, before any AIFM, depositary or administrator invoice arrives.

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.
• 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. Familiarity and administrator footprint usually decide it.
• 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) actually undercuts Jersey's headline fees, so price is no longer the tiebreak it once was. The choice tends to fall to where your administrator and directors already sit and which island's board/substance you can staff fastest.
• Single-family or club money? A Guernsey Family PIF is the lightest-touch of the set; a JPF works equally well for a small club deal. Neither needs the Luxembourg/Ireland machinery.

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.