ELTIF (European Long-Term Investment Fund)

An ELTIF (European long-term investment fund; FILPE in the Spanish version of the rules) is an EU alternative investment fund authorized under Regulation (EU) 2015/760 to channel capital into long-term investments in the real economy. Only an EU AIF can obtain that authorization, which is valid in all Member States (Article 3(1) and 3(2)), and it is managed by an authorized EU AIFM or, where its legal form allows, internally (Article 2(12)). ESMA keeps a central public register of ELTIFs (Article 3(3)). The regulation has applied since December 9, 2015 (Article 38).

ELTIF 2.0. Regulation (EU) 2023/606 amended the regime and has applied since January 10, 2024 (Article 2). ELTIFs authorized before that date are deemed compliant until January 11, 2029, or indefinitely if they do not raise additional capital.

Eligible assets. An ELTIF may only invest in eligible investment assets and in the assets listed in Article 50(1) of the UCITS Directive (Article 9(1)), and it must invest at least 55% of its capital in eligible investment assets (Article 13(1); 70% before the reform). Eligible investment assets are (Article 10(1)):

• equity, quasi-equity or debt instruments issued by a qualifying portfolio undertaking, and loans to that undertaking;
• units of other ELTIFs, EuVECAs, EuSEFs, UCITS and EU AIFs managed by EU AIFMs, if they invest in eligible investments;
• real assets;
• simple, transparent and standardized securitizations with certain underlying exposures, and European green bonds issued by qualifying portfolio undertakings.

As a general rule, a qualifying portfolio undertaking cannot be a financial undertaking, and if it is listed, its market capitalization cannot exceed EUR 1.5 billion at the time of the initial investment (Article 11(1)). An ELTIF cannot short sell, take exposure to commodities or use derivatives except to hedge risks (Article 9(2)).

Retail access. An ELTIF can be sold to retail investors with these safeguards:

• a suitability assessment under Article 25(2) of MiFID II, including for purchases on the secondary market (Article 30(1));
• a written alert if the fund's life exceeds 10 years (Article 30(2));
• the right to cancel the subscription without penalty during the subscription period and for two weeks after signing (Article 30(7));
• a prospectus and, for retail investors, a key information document under the PRIIPs Regulation (Article 23(1));
• borrowing of up to 50% of net asset value, compared with 100% if marketed only to professional investors (Article 16(1)(a)).

The reform removed the EUR 10,000 minimum initial investment and the 10% portfolio cap that applied to retail investors with portfolios of up to EUR 500,000 (recital 47 of Regulation 2023/606). We explain the difference between retail and professional clients in retail vs professional investors.

Liquidity. As a general rule, investors cannot request redemption before the end of the fund's life (Article 18(1)). The fund rules may allow redemptions during the fund's life, subject to conditions (Article 18(2), possible since 2015 and revised by the reform), and, since 2024, matching of exiting and incoming investors' requests (Article 19(2a)).

ELTIFs and tokenization. ELTIF units are financial instruments (Annex I, Section C, of MiFID II) and can be recorded on DLT where the law of the fund's home state allows it. An ELTIF's rules cannot prevent its units from being admitted to trading on a regulated market or a multilateral trading facility (Article 19(1)). But today they cannot be traded on a DLT Pilot Regime infrastructure: among fund units, Article 3(1) of Regulation (EU) 2022/858 only allows those of non-structured UCITS, and an ELTIF is an AIF. The European Commission's proposal COM(2025) 943 would remove that limit, but it is still going through the legislative process. The full analysis is in tokenized funds in Europe.

In Spain. The name FILPE is reserved for funds set up under Regulation 2015/760 and entered in the CNMV register (Article 40 bis of Law 22/2014). Spain's Law 6/2023 recognizes DLT as a way to represent transferable securities (Article 6(1)), and the steps for a Spanish fund are in how to tokenize an investment fund in Spain.

Official sources: Regulation (EU) 2015/760, consolidated text (EUR-Lex); Regulation (EU) 2023/606 (EUR-Lex); Regulation (EU) 2022/858 (EUR-Lex); Spain: Law 22/2014, Article 40 bis (BOE). Framework verified as of October 13, 2026. Considering an ELTIF with tokenized units? Talk to us.