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disclosure regimes · European Union

What European private credit funds must disclose, and to whom

Under Article 23(4)(d) of Directive 2011/61/EU as amended, a manager must periodically disclose the composition of its originated loan portfolio to investors. That disclosure is made to investors, not to the public.

the dates

  1. 20 March 2023Regulation (EU) 2023/606 — ELTIF 2.0 — is published in OJ L 80. It applies from 10 January 2024; funds authorised before that date are deemed compliant until 11 January 2029.
  2. 26 March 2024Directive (EU) 2024/927 — AIFMD II — is published in the Official Journal.
  3. 16 April 2026Transposition and application, including the new investor disclosures and the rules on loan-originating funds: 20% concentration per borrower where the borrower is a financial undertaking, leverage capped at 175% for open-ended and 300% for closed-ended loan-originating funds, 5% retention on loans transferred, and a ban on originate-to-distribute.
  4. 16 April 2027The rewritten Article 24 on supervisory reporting applies. ESMA must submit the corresponding technical standards to the Commission by the same date.
  5. 10 January 2030ESMA’s central public registers — of authorised managers and their funds, and of authorised ELTIFs — become accessible on ESAP.

What becomes machine readable

ESMA’s central public register identifying each authorised manager, its competent authority and the list of funds it manages or markets in the Union. For ELTIFs, the register also carries the LEI, the ISIN of the fund and of each unit class, the Member States of marketing, whether it may be marketed to retail investors, and the dates of authorisation and of first marketing.

granularity · Fund level — identification only. Nothing at position level.

What stays out of reach

The composition of the loan portfolio goes to investors, not to the public, and does not enter ESAP. Annex IV reporting under Article 24 stays confidential even once enriched in 2027 — ESMA publishes aggregates, not fund-level data. There is no European equivalent of Form N-PORT Item C.8 or of a tagged Schedule of Investments.

What it changes for the measurement

Under current law there is, and will be, no public European source allowing the measurement we publish in the United States to be reproduced. We would rather write that plainly than imply a European product is around the corner. The one open path runs through listed issuers under the Transparency Directive, via ESAP from July 2027 — a different measurement, on a different population.

primary sources

this page describes what the texts say · it is not legal advice, and the official text always governs · where we could not read a primary source, we have left the point out rather than paraphrase it