ELTIF 2.0 What the reform changed for investors - and what it didn't 

Two years after the entry into force of ELTIF 2.0, the reform has arrived in the market. Read what it has changed and what it means for existing ELTIF investments here.
Time to read12 min.
updated at06/10/2026
CategoryELTIFs
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Contents

Why was the ELTIF reformed? 

The ELTIF was reformed because the original set of rules blocked its own objectives. By the end of 2022, there were only 77 ELTIFs across Europe with a volume of around EUR 11 to 12 billion. For retail investors, access to high minimum investments and asset thresholds was linked, while for fund providers, the requirements for assets and diversification were too tight. With ELTIF 2.0, the EU has reduced these hurdles as of 10 January 2024.

With the ELTIF (Long-Term Investment Fund), the EU launched a brand new financial instrument in 2015. The ELTIF was designed to make it easier for investors to invest their money directly in the European real economy - for example, in projects in the areas of infrastructure, real estate and renewable energies, as well as private equity and private debt.

ELTIFs were thus designed as a bridge between the real economy and the financial market. Until now, access to areas such as infrastructure, private debt or private equity has mainly been restricted to institutional investors or very wealthy customers. Private investors, on the other hand, had hardly any opportunity to invest their capital in the real economy without detours before the ELTIF was launched. The ELTIF should provide a remedy here and also enable private investors to access innovative investments in tangible assets.

However, despite the visible growth of the ELTIF market, the development and popularity of the new investment product fell far short of expectations.

The difficulty lies mainly in the strict regulations: This is because the ELTIF has been equipped with a comprehensive set of rules to protect investors. For example, private investors were allowed to invest at least EUR 10,000 but no more than 10% of their net assets. This means that Private investors had to have net assets of at least EUR 100,000 to be able to invest in ELTIFs. Those with more than EUR 500,000 in liquid assets were also allowed to invest more than 10% in ELTIFs.

This has paralysed the dynamics in the ELTIF market, especially for retail investors. The potential that the financial instrument actually offers was therefore far from being exploited. The EU has recognised this and adopted a comprehensive ELTIF update on 10 January 2024 - the ELTIF 2.0.

The new regime became fully operational with the final regulatory technical standards that entered into force in October 2024.

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The large ELTIF reference work

Is there a secondary market for ELTIFs? What happens at the end of the term? What role does an ELTIF play in the portfolio? You can find answers to these and other questions in the large ELTIF Guide.

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What has changed with ELTIF 2.0?

ELTIF 2.0 had the reform initiated at the two points that had actually blocked the old rules: The minimum investment amounts and asset thresholds for private investors have been eliminated and the range of eligible assets has been significantly extended. An overview of the most important changes:

  • Elimination of minimum investment amounts: Private investors do not need a minimum investment of EUR 10,000 or net assets of EUR 100,000 more.
  • Expanded investment universe: Securitisations, green bonds, investments in other EU-regulated funds, commercial real estate projects and smaller tangible assets are now also permitted.
  • Higher lever: The maximum borrowing increased from 30 to 50 percent of the fund assets.
  • Eased portfolio ratio: At least 55 per cent instead of 70 per cent of the fund capital must flow into eligible assets.
  • Higher concentration allowed: An individual investment can now account for up to 20 per cent instead of 10 per cent of the fund assets.
  • Stricter transparency obligations: ELTIFs are subject to extended information and disclosure rules to investors.


In which assets can ELTIFs now invest?

With the new rules, fund providers have significantly more choice in the design of ELTIFs. The spectrum of eligible assets was expanded with the update and now includes not only classic tangible assets but also simple securitisations and green bonds from qualified portfolio companies. Small and medium-sized enterprises (SMEs), real estate and even commercial real estate projects can now also be included in ELTIF portfolios. In addition, they can now also invest in EU-regulated investment funds, as long as these funds themselves invest in securities eligible for ELTIFs.

In addition, the minimum value of EUR 10 million for tangible assets was deleted. The funds can now also invest in lower-value assets.

All these innovations give capital management companies that launch ELTIFs significantly more leeway in the design of fund portfolios and enable them to achieve much greater diversification in the portfolio. This ensures broader risk diversification, which in turn increases stability for investors.


ELTIF 2.0 offers more opportunities for retail investors

Especially for private investors themselves, perhaps the most important change is that the previous minimum investment amounts have been lifted: While up until recently at least EUR 10,000 could be invested in ELTIFs and a maximum of 10% of the net assets in ELTIFs, these investment restrictions have been reduced with the ELTIF 2.0. This eliminated one of the greatest hurdles that has so far dampened the popularity and growth of the ELTIF market.

With the update, investors now have unrestricted access to the ELTIF market and numerous innovative investments - trending upwards. The regular MiFID II requirements apply to distribution to retail investors. Depending on the distribution channel, a suitability or appropriateness check is carried out. Investors are informed in detail about the opportunities and risks of ELTIFs.


What transparency obligations apply under ELTIF 2.0?

The revised ELTIF 2.0 Regulation increases transparency requirements for ELTIFs. In detail, this means that they are subject to stricter information obligations towards investors. This transparency helps to strengthen confidence in the investment product ELTIF and make it more accessible to private investors.

At the same time, the additional information helps investors to obtain detailed information about the investment products offered and make more informed investment decisions.


Tax incentives remain in place

Through tax incentives, some EU Member States aim to further promote investments in ELTIFs - for example in the form of tax advantages or exemptions.

klimaVest portrait: The largest European ELTIF1 for retail investors

  1. Track record: As the current Scope ELTIF study reports, klimaVest is the largest ELTIF1 in Europe, which is also sold to private investors. Since its launch in 2020, the tangible assets fund has built up a diversified portfolio of over 43 assets in 6 European countries.

    klimaVest is thus demonstrating that tangible assets in the renewable energy sector offer a lot of future potential - and above all attractive return opportunities for its investors.
     
  2. Tangible assets with future: klimaVest invests the capital of its investors directly in tangible assets in the field of wind and solar power, as well as transmission networks and, in the future, storage solutions.

    klimaVest and its investors actively take responsibility for the energy transition in Europe and work actively to promote, advance and revolutionise renewable energies.
     
  3. Innovative: Pioneering spirit is in the DNA of klimaVest. That’s why wind and solar are just the beginning: klimaVest also finances transmission networks and, in the future, storage solutions with long-term purchase agreements - i.e. those structures that ensure the functionality, performance and future viability of the energy supply.
Find out more about klimaVest

ELTIF vs. ELTIF 2.0 in direct comparison

Erlaubte Anlagewerte
ELTIFInfrastruktur, Erneuerbare Energien, Private Equity, Private Debt
ELTIF 2.0Ergänzung um grüne Anleihen, Verbriefungen, OGAWs und alternative Investmentfonds (AIFs)
Liquidität
ELTIFInvestment von min. 70 % des Fondskapitals in illiquide Vermögenswerte
ELTIF 2.0Investment von min. 55 % des Fondskapitals in illiquide Vermögenswerte
Hebel/Kreditaufnahme
ELTIFMaximal 30 % des Fondsvermögens
ELTIF 2.0Maximal 50 % des Fondsvermögens
Konzentration je Investment
ELTIFMaximal 10 % des Fondsvermögens pro Einzelinvestment
ELTIF 2.0Maximal 20 % des Fondsvermögens pro Einzelinvestment
Funktion als Dachfonds
ELTIFInvestment nur in andere ELTIFs möglich
ELTIF 2.0Investment auch in andere Fondsarten möglich
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Opportunities & risks of the ELTIF reform

What opportunities does ELTIF 2.0 offer retail investors?

  • New investment opportunities: Private investors gain access to new investments that were previously primarily only accessible to institutional investors. These include real estate companies and infrastructures, private equity and other investment funds. These new investment opportunities can significantly increase the return expectations of ELTIFs.
Infrastructure funds

Infrastructure as an asset class

Renewable energies, electricity grids, transport routes: Infrastructure is one of the most important asset classes for long-term investments in tangible assets. This article explains what options are open to private investors today and what role infrastructure funds play in the energy transition.

Read it now.
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  • Greater diversification: The new investment opportunities give retail investors the opportunity to benefit from a larger number of assets with just one fund investment. This is mainly due to the significantly reduced investment hurdles as well as the so-called “fund of fund” structure, with which ELTIFs can now also invest in other investment funds. This allows retail investors to diversify their portfolio more, reduce their investment risks and increase their return opportunities.
  • Lower minimum investment amounts: By lowering the minimum investment amounts and requirements for the prescribed liquidity of investors, access barriers were significantly reduced. This enables significantly more investors to make long-term investments in ELTIFs and the European real economy.
  • More product selection on the market: At the end of 2022, there were 77 ELTIFs across Europe; by the end of 2025, there were already 268.2 Private investors can now choose between different strategies, providers and focus areas - from renewable energies to infrastructure to private debt.
  • New sales channels: ELTIFs have also been accessible via digital platforms and neobrokers since 2025. Today, it is just as easy to subscribe to an ELTIF as it is to subscribe to a classic investment fund.
  • Clearer rules for returns during the term: Prior to the reform, there were hardly any requirements for ELTIFs with a redemption option during the term. With ELTIF 2.0 and the final regulatory standards of October 2024, these structures are explicitly regulated for the first time. Since then, retail investors have found a broader range of products with clear return rules.

 

What are the new risks of switching to ELTIF 2.0?

The reform has opened up the ELTIF market to retail investors and, at the same time, triggered a wave of new products that make the segment confusing. Those who want to invest in ELTIFs now have to check more carefully than before whether a fund is solidly designed and comes from a company with genuine tangible value expertise. This assessment includes five concrete risks that did not exist in this form before 2024.

  • Vendors without a track record: At the end of 2022, there were 77 ELTIFs, and at the end of 2025 there were already 268. In 2025 alone, 56 asset managers first entered the market with an ELTIF.2 Many of these companies do not yet have a reliable history with the ELTIF vehicle. The rating agency Scope therefore expressly warned in March 2026 of a “reputational risk from inexperienced providers” and of how sensitive the perception of the segment is to weaknesses in individual products.3
  • Fund labels do not always reveal the content: The reform has increased not only the number of ELTIFs, but also the range of strategies. Terms such as “multi-asset” or “infrastructure” often say little about the actual content of a fund. Investment experts from Stiftung Warentest wrote in April 2026: "If the ELTIF prospectus states 'multi-asset', everything can be hidden behind it - from private equity to renewable energies. And even if the focus is on 'infrastructure', it is not always clear what exactly is meant by it."4
  • Limited diversification: The new ELTIF Regulation allows up to 20% of the fund assets to be invested in a single investment. This means that an ELTIF with only five investments can comply with the statutory diversification rules. In October 2025, Verbraucherzentrale Baden-Württemberg explicitly compared this with a broadly diversified index fund and sees the illiquidity associated with this concentration as a major risk.5

    It is easy to understand what real diversification looks like at klimaVest. The fund distributes its capital to 43 tangible assets in 6 European countries, with a focus on photovoltaic, wind and grid installations. Instead of approaching the regulatory cap of 20% per investment, the fund is broadly diversified across several countries and investment types.
  • "Semiliquid" does not mean “liquid”: With ELTIF 2.0, open and semi-liquid ELTIFs were explicitly regulated for the first time. Many new products promote regular returns - usually quarterly. Retail investors can easily get the impression that a semi-liquid ELTIF is similarly liquid to a classic equity or bond fund. That’s not right. Normally, the returns will work as announced. In the event of stress, they can be capped or temporarily suspended entirely.
  • Discontinuation of the asset threshold: Prior to the reform, the entry into an ELTIF was in fact linked to an investment portfolio buidling at least EUR 100,000: Minimum EUR 10,000 investment amount and maximum 10% of the portfolio in ELTIFs. Both hurdles have been removed, some providers now accept subscriptions from 1 euro. This means that an ELTIF can seem like a simple take-away product - but it is still a complex, long-term investment in tangible assets that requires its own assessment. 

    Overall, ELTIF 2.0 shifts the responsibility more towards investors. Ultimately, it is important whether the fund concept is understandable, whether the ELTIF is backed by asset management with real tangible value expertise and whether the fund itself can demonstrate a reliable track record.

Regulations: What are the legal requirements for ELTIF 2.0?

The regulatory requirements for ELTIFs have been laid down in Regulation (EU) 2015/760 on European Long-Term Investment Funds (ELTIF Regulation) and updated by Regulation (EU) 2023/606 (also known as ELTIF 2.0). Many aspects of the practical requirements that ELTIFs must follow in the future are also set out in the so-called RTS (Regulatory Technical Standards).

These are the main requirements imposed by the Regulation for ELTIF 2.0:


Eligible assets and investment restrictions

The assets eligible for ELTIFs as investment are defined in Articles 9 to 13 of the ELTIF Regulation. It also sets out the specific investment restrictions to which ELTIFs are subject.

This includes, on the one hand, the expansion of the investment universe with ELTIF 2.0. This scheme allows investments in a wider range of assets, including SMEs, real estate and infrastructure projects (Articles 10 and 11).

On the other hand, diversification requirements are also defined: As a rule, an ELTIF may not invest more than 20 per cent of its capital in a single asset or issuer. This is to ensure an appropriate risk distribution for investors (Article 13).


Leverage and borrowing

Article 16 governs borrowing and the use of leverage under ELTIF 2.0. The update allows the maximum leverage to be increased to 50 percent of the fund assets.

Prior to the update of the ELTIF Regulation, the maximum leverage was 30 percent.


Licencing and registration

Articles 5 to 8 regulate aspects relating to the authorisation and registration of ELTIFs. These Articles provide that an ELTIF must be approved by the competent national supervisory authority before it may be marketed.

This also includes compliance with the AIFM Directive, which governs the management of alternative investment funds, as well as specific requirements of the ELTIF Regulation.


Requirements for distribution to retail investors

Distribution to retail investors is subject to specific requirements laid down in Articles 30 to 32 of the ELTIF Regulation.

This also includes the aspect of suitability testing. The regular MiFID II requirements apply to distribution to retail investors. As part of investment advice, it must be ensured that the investment is suitable for the respective investor. This is based on the financial situation as well as the respective individual investment objectives (Article 30). 

With ELTIF 2.0, the minimum investment amounts and asset thresholds for retail investors have also been eliminated. However, bidders may set their own minimum amounts in their sales documents.


Redemption conditions and liquidity management

Articles 18 and 19 of the ELTIF Regulation set out the redemption conditions and liquidity management.

This also includes the illiquidity requirements applicable to ELTIFs: An ELTIF must in principle be illiquid, but can offer regular redemption opportunities. This serves to better meet the needs of retail investors (Article 18).


Reporting and transparency

Articles 22 to 26 of the Regulation set out the regulatory requirements for the reporting and transparency of ELTIFs.

Among other things, the extended disclosure obligations are defined here: ELTIFs must provide detailed information on the investment strategy, risks, cost structure and performance of the Fund (Article 23).

These disclosure obligations are supplemented by the requirement for regular reporting: ELTIFs are therefore required to submit regular reports to regulators and investors in order to ensure their transparency (Article 24).


Risk management and governance

Articles 27 and 28 define the risk management and governance requirements for ELTIFs.

This also includes the regulations regarding risk management systems: ELTIFs must implement robust risk management systems to manage the specific risks of their assets and their illiquid nature (Article 27).

Measures to avoid conflicts are also prescribed: This regulation obliges the fund management to implement measures to avoid conflicts of interest (Article 28).

Frequently asked questions about ELTIF 2.0 

The reform of ELTIF 2.0 opens the door to several new asset classes that were previously unavailable, such as green bonds, securitisations and units in UCITS and alternative investment funds (AIFs).

In addition, ELTIF 2.0 makes existing asset classes, such as unlisted companies, SMEs and infrastructure projects, significantly more accessible and attractive through relaxed regulations and expanded definitions. For example, the previous minimum threshold of EUR 10 million for individual investments in tangible assets has been eliminated.

Semi-liquid funds within the meaning of ELTIF 2.0 are investment funds that mainly invest in long-term, less liquid assets, but still offer regular redemption opportunities. These funds combine elements of open-ended and closed-ended funds, providing periodic liquidity through planned redemption windows while maintaining long-term investments.

This offers investors access to illiquid markets with the option to exit before maturity - within the framework of the respective fund conditions.

Theoretically yes. The “European” component of the name does not bind ELTIFs to Europe as an investment region, but only refers to the European regulatory framework. ELTIFs are allowed to invest worldwide and in practice many funds also use this: Some providers focus on developed countries, others look around the world, and individual funds even invest specifically in emerging markets.

However, there is doubt as to whether this is always in the interests of European private investors. Europe offers a stable legal and political framework for long-term investments. An ELTIF with a focus on solar farms in the Southern Sahara may offer attractive return opportunities, but carries risks that a private investor portfolio does not necessarily need. Anyone subscribing to an ELTIF should therefore consider where the fund actually invests, not just which asset class it belongs to.

ELTIF 2.0 particularly benefits industries such as infrastructure, real estate, renewable energies and small and medium-sized enterprises (SMEs). Expanded investment opportunities in infrastructure projects and real estate development, as well as easier access to SME financing, provide these sectors with additional cash flow.

The private equity sector is also benefiting from increased investments in unlisted companies, which leads to more growth capital for innovative and high-growth companies.

The implementation of ELTIF 2.0 also presents challenges, such as ensuring sufficient liquidity in semi-liquid funds and compliance with the extended regulatory requirements, in particular with regard to risk management and investor protection.

There are also technical and operational hurdles to meet the requirements for transparency and regular reporting. In addition, fund management must find the right balance between opening up new asset classes and maintaining investor protection. In addition, regulatory differences between EU Member States could complicate the harmonisation and cross-border distribution of ELTIFs.

Yes, ELTIF 2.0 can invest in other funds to a limited extent. They may invest in other ELTIFs, European Venture Capital Funds (EuVECA), European Social Entrepreneurship Funds (EuSEF) and Alternative Investment Funds (AIFs), which also focus on long-term investments in eligible assets.

These investments must comply with the diversification and risk management requirements of the ELTIF Regulation and may not exceed 20 per cent of the value of the ELTIF portfolio.

The market has grown rapidly since 2024. More than 268 ELTIFs have now been authorised in Europe, of which 113 new issues in 2025 alone.2 However, this development is not always to the benefit of retail investors.

In April 2026, Stiftung Warentest found in a study of 29 ELTIFs distributed in Germany that almost all funds did not enter the market until after the 2024 reform. Only klimaVest has existed since 2020 and, with a fund volume of 1.8 billion euros, is still Europe’s largest ELTIF for private investors.2 Resilient multi-year histories are correspondingly rare, and many 2.0 new issues advertise more with model returns than with returns achieved. 

Sonja Knorr, analyst at Scope, derives a clear recommendation: "Since you don't know in advance whether an ELTIF will be successful with its investments, investors should choose providers with a strong history. Such established companies have already proven that they can also be successful in difficult market phases".6

New opportunities also open up for existing ELTIFs, as it is possible to transfer an existing product under ELTIF 1.0 to ELTIF 2.0. Providers of already successful funds can therefore first observe the effects of the regulatory changes and then switch their funds if it seems appropriate. Tried-and-tested system concepts do not need to be converted overnight. 

Access requirements can be simplified by adding newly authorised asset classes to portfolios on a selective basis - without changing the core of a tried-and-tested concept. Scope analyst Sonja Knorr recommends retail investors to choose “provers with a strong history” anyway, because such established companies would have “already proven” that they are successful even in difficult market phases.6 For the first generation of ELTIFs, this speaks more for consolidating their strengths than giving them up.

No. If you have a first-generation ELTIF in your custody account and it performs according to your expectations, you do not need to switch. You can watch the track record of the newly launched funds develop in peace and quiet.

The benefits of the reform are mainly related to entry, such as the elimination of the minimum investment amount and the asset threshold. Anyone who has already invested does not benefit additionally. On the contrary. The other 2.0 changes, such as higher permitted leverage or higher concentration per individual investment, increase the risk to first-generation ELTIFs. From the investor’s point of view, switching just because of the “2.0” label makes little sense.

If you are considering a change, then based on specific criteria: How convincing is the fund concept? What is the experience of asset management? Can the fund already demonstrate a resilient performance? These questions are irrespective of whether an ELTIF was launched under 1.0 or 2.0.

1Largest ELTIF / Market Leader in Germany: Scope ELTIF Study 2026, “Successful Mass Launch – Overview of the ELTIF Market 2025/2026,” as of December 31, 2025, published March 26, 2026, pages 2 and 9.

2Source: Scope ELTIF Study 2026, https://www.dasinvestment.com/eltif-markt-rekord-bei-neuauflagen-volumen-springt-auf-34-milliarden/

3Source: Börsen-Zeitung, March 26, 2026, https://www.boersen-zeitung.de/banken-finanzen/neo-broker-treiben-deutschen-eltif-markt

4Quelle: Stiftung Warentest Finanzen 04/2026, Seite 38, Online-Übersicht: https://www.test.de/Eltif-europaeische-Langfristfonds-ueberblick-6286734-0/

5Source: Consumer Advice Center, October 31, 2025, https://www.verbraucherzentrale.de/wissen/geld-versicherungen/sparen-und-anlegen/eltifs-neue-anlageform-mit-tuecken-96375

6Source: Frankfurter Allgemeine Sonntagszeitung, 26.04.2026, Dennis Kremer (Print-Ausgabe)