Regulation (EU) 2023/606 reformed the European long-term investment fund: since January 10, 2024, the €10,000 minimum and the 10% cap for retail investors are gone. Infrastructure, private equity and private debt can now be distributed with a MiFID suitability test.
Want to launch or distribute an ELTIF? Tell us about it
Tell us whether you are a fund manager or a distributor and what strategy you have in mind, and we will walk you through the full regulatory path.
Six building blocks so your long-term vehicle reaches the market with the right structure and a distribution model that withstands supervisory review.
We define the strategy, eligible assets, redemption policy and fund documentation, and handle the entire application process: a poorly designed ELTIF shows years later, when investors are already in.
ELTIF 2.0 replaced the entry thresholds with the MiFID suitability test: we set up the assessment, warnings and client information process so that every retail sale is documented and defensible.
An authorized manager is the starting point. We support you with authorization, resources and ongoing compliance.
The ELTIF sits within the alternative investment fund manager framework: liquidity, delegation and reporting rules apply to it too.
Not every strategy needs an ELTIF. We compare vehicles by target investor, assets and distribution.
Target market, channel and periodic review: a retail ELTIF requires a flawless product file.
Four players in the Spanish market for whom the reform changes the math: fund managers, distributors and advisers with retail clients.
“Our infrastructure funds only reached institutional investors. With ELTIF 2.0 we can open the strategy to retail investors without the straitjacket of the €10,000 minimum, and that multiplies the market we sell to.”
“Our clients are asking for private markets. The ELTIF lets us offer them within a clear framework: suitability test, cost disclosure and a European product recognized across the whole network.”
“Recommending private equity to a retail client was almost impossible to fit in. Now I can include ELTIFs in long-term proposals, as long as the suitability test and the client’s horizon support it.”
“We finance energy infrastructure over fifteen years. An ELTIF connects us with stable European retail savings, something no traditional open-ended fund could give us.”
The first version of the ELTIF barely took off. Regulation (EU) 2023/606 tackled the three barriers holding it back, with effect from January 10, 2024.
Retail entry barriers fell: the €10,000 minimum investment and the 10% cap on the retail client’s portfolio are gone. Instead, the gateway is the MiFID suitability test, with its associated warnings and information.
Broader asset universe: ELTIF 2.0 widens the vehicle’s eligible assets, making room for more infrastructure, private equity and private debt strategies and making diversified long-term portfolios easier to build.
More flexible liquidity: the new regime gives managers more room to design the fund’s life and its redemption options in line with the applicable rules, bringing the product closer to what a retail investor can understand and accept.
| Aspect | ELTIF 1.0 | ELTIF 2.0 |
|---|---|---|
| Retail access | €10,000 minimum and a 10% cap on the client’s financial portfolio | No minimum and no 10% cap: access through a MiFID suitability test with warnings and client information |
| Eligible assets | A restrictive universe that left many real-world strategies out | Expanded eligible assets: more room for infrastructure, private equity and private debt |
| Liquidity | A rigid regime, hard to reconcile with retail demand | More flexibility to design redemptions and the fund’s life on the terms set by the rules |
We structure the vehicle, prepare the documentation and build the retail distribution with you: suitability test, product governance, cost disclosure and warnings. So your ELTIF sells private markets without buying you a problem with the supervisor.
The ELTIF (European Long-Term Investment Fund) is the EU’s long-term investment vehicle: a fund governed by an EU Regulation and designed to channel capital into infrastructure, private equity and private debt, assets that need long horizons.
Its EU label is its main commercial asset: a single regime recognized across the EU, managed by a manager authorized under the alternative investment fund framework.
The reform is Regulation (EU) 2023/606, applicable since January 10, 2024. Three changes drive the relaunch:
Yes, if they pass the right filter: retail distribution requires a MiFID-style suitability assessment (knowledge and experience, financial situation, objectives and horizon), plus the information and warnings that apply in each case.
For distributors, the message is clear: an automatic €10,000 threshold no longer protects you. What protects you is a well-run test, documented and consistent with the recommendation. Suitability evidence is now the centerpiece of the sales file.
A manager authorized under the EU framework for alternative investment fund managers; in Spain, typically an SGIIC with the appropriate program of activities. Managing an ELTIF is also subject to AIFMD II: liquidity management, delegation and reporting.
If you do not have a manager yet, the project starts earlier: first the authorization of the entity, then the design and registration of the vehicle.
In long-term assets permitted under its regime: infrastructure projects (energy, transport, digital), private equity holdings in unlisted companies and private debt, among other eligible assets that the 2023 reform expanded.
The detailed work lies in fitting your specific strategy into the eligible categories and the applicable diversification limits: this upfront analysis avoids having to redesign the fund in the middle of fundraising.
It is not a money market fund, and no one should sell it as one. It is a long-term product whose liquidity depends on how each vehicle is designed: ELTIF 2.0 allows structures with redemption options in line with the rules, but the starting point is still a time commitment.
That is why the sales conversation matters so much: the client’s horizon, liquidity needs and clear warnings. An ELTIF sold to someone who needs the money in two years is a complaint in the making.
Because it opens a market to retail investors that used to be closed. For managers, it is a way to raise stable capital beyond institutional investors, under an EU brand. For distributors (banks, platforms, advisers), it is the regulated way to meet demand for private markets without inventing exotic structures.
The trade-off is rigor: a long-term product, an assessed client and a complete distribution file. Those who do it well will have a distinctive product; those who do it fast will have a problem.
Four building blocks:
We can run the whole project or step in on the piece you are missing; start with IIC authorization.
A successful ELTIF is built on two fronts at once: the vehicle (structure and authorization) and distribution (suitability and evidence). This is our roadmap.
We confirm that your strategy fits within the eligible assets, define the fund’s life and redemption policy, and decide whether the ELTIF is the right vehicle compared with alternatives such as the FCR. This is where the project is won or lost.
Fund rules, prospectus, investor documentation and the application to the supervisor, with the AIFMD II fit resolved: the vehicle’s liquidity, valuation, delegation and reporting documented from day one.
Distribution agreements, target market, suitability test, warnings and cost disclosure. Every retail sale should leave a file you can show the supervisor without editing it first.
Need end-to-end support? Start with IIC authorization, review our services for SGIICs and secure the sale with a well-built suitability test.
From the product committee to the sales network, these are the concepts your team must handle precisely to launch and distribute an ELTIF.
A vehicle governed by an EU Regulation to invest in long-term assets under a single EU label.
Reform applicable since January 10, 2024: it removes retail barriers, expands eligible assets and makes liquidity more flexible.
Infrastructure, private equity and private debt: long-horizon assets traditionally reserved for institutional investors.
The ELTIF’s catalog of permitted investments, expanded by the 2023 reform. Each strategy must be fitted in before launch.
MiFID assessment of knowledge, financial situation and objectives that replaces the €10,000 minimum and the 10% cap.
The ELTIF 1.0 minimum investment that, together with the 10% cap on retail portfolios, stifled distribution. It no longer exists.
The design of the fund’s life and exit windows in line with the rules. More flexible in 2.0, but still a long-term product.
The product governance definition of the client the ELTIF is aimed at, and of the client it must not be sold to.
Banks, platforms and advisers that market the ELTIF: the suitability test, warnings and cost disclosure are their responsibility.
A strategy that fits the eligible assets, with a fund life and redemptions consistent with the portfolio’s real liquidity.
Eligibility memo by asset type, redemption policy and liquidity analysis of the design.
An authorized manager with adequate resources, and the liquidity, delegation and reporting obligations of the alternative fund framework addressed.
Program of activities, updated manager policies and reviewed delegation agreements.
Fund rules, prospectus and investor information that are complete, clear and consistent with each other, registered with the supervisor.
Registration file, approved versions of the documentation and responses to requests for information on file.
A suitability test that is genuinely applied, warnings delivered and ex ante cost disclosure in every sale.
Suitability files for each client, records of information delivered and approved marketing materials.
Periodic review of the target market, control of off-profile sales and monitoring of the fund’s liquidity.
Product governance reports, committee minutes and a distribution and complaints dashboard.
Any of these five situations ends the same way: requests for information, complaints or a fund that fails to raise capital. Better to spot them now.
Launching and distributing an ELTIF spans three worlds: the regulation of managers and vehicles, the rules on retail distribution and the EU agenda on long-term investment. These pages help you see the whole board before you make a move.
The alternative investment fund managers directive, applicable since April 2026: liquidity, delegation and reporting rules for your ELTIF too.
The EU agenda (RIS) that will shape how products are sold to retail investors: value for money, inducements and more.
The key information document for packaged retail and insurance-based investment products: a mandatory part of the sales file.
Private equity, debt and co-investment: the legal work on the deals that will fill your ELTIF’s portfolio.
And if the project calls for a different structure, compare it with the venture capital fund, consider the SGIIC as manager or see the venture capital fund manager. For the sales side, everything starts with the suitability test.
Tell us about your ELTIF project (strategy, target investors, distribution channel) and we will tell you what you need to launch it and sell it with confidence.
The ELTIF (European long-term investment fund) is the vehicle created by the EU to channel savings into infrastructure, private equity and private debt under a single label recognized across the internal market. Its first version barely worked; the reform known as ELTIF 2.0 (Regulation (EU) 2023/606, applicable since January 10, 2024) removed the barriers holding it back and has made it the leading regulated route for bringing private markets to European retail investors.
The most talked-about change in the reform is the removal of the two retail barriers of ELTIF 1.0: the €10,000 minimum investment and the rule that prevented retail investors from putting more than 10% of their portfolio into the product. Instead, ELTIF 2.0 relies on the MiFID suitability test for access: the distributor assesses the client’s knowledge, financial situation, objectives and horizon, and documents that the product fits. The filter is no longer arithmetic but professional, which shifts the weight (and the burden of proof) onto each firm’s suitability process.
The reform expands the eligible assets, making room for more real-world infrastructure, private equity and private debt strategies, and gives managers greater flexibility to design the vehicle’s liquidity in line with the applicable rules. The ELTIF is still a long-term product (that has not changed and will not change), but the design of the fund’s life and redemption options now allows more marketable configurations. Design discipline matters: the liquidity offered to investors must match the portfolio’s real liquidity, and that analysis must be documented.
For an SGIIC or a venture capital fund manager, the ELTIF opens up a retail investor base that traditional private markets vehicles could not reach. For banks, platforms and advisers, it is the regulated answer to growing demand for decorrelation and long-term income. The condition is to execute both legs well: a vehicle whose strategy fits the regime, and distribution with product governance, suitability and warnings that withstand supervisory review.
The ELTIF cannot be analyzed in isolation. Managing the vehicle falls under the alternative fund manager framework, which AIFMD II has strengthened since April 16, 2026 (liquidity, delegation, reporting), and its retail sale will take place on the ground mapped out by the Retail Investment Strategy, still under negotiation. Our advice: design the fund and its distribution today with both factors in view, and avoid building a product that has to be reworked in its first year. If you want to weigh alternatives, compare it with the venture capital fund.
Key legislation, linked to the official text:
Legislation and links reviewed in .