AIFMD II compliance infrastructure for loan-originating AIFs

European private credit funds are entering a new regulatory regime. AEGIS helps AIFMs monitor loan-originating fund limits, identify exceptions, and generate board-ready compliance evidence from portfolio data and loan documents.

Built in Luxembourg for EU AIFMs, private credit managers, fund CFOs, risk teams, and compliance officers.

The Regulatory Trigger

AIFMD II turns loan origination into an ongoing control problem

Loan-originating AIFs can no longer rely only on periodic manual reviews. Compliance teams need live visibility over fund exposures, borrower limits, risk retention, leverage, liquidity controls, and board evidence throughout the full fund lifecycle.

Risk retention

Track 5% retention requirements and transfer restrictions across every originated loan.

Concentration limits

Monitor borrower, group, and restricted counterparty exposure against fund and regulatory thresholds.

Leverage monitoring

Compare actual leverage against fund-level and regulatory limits on an ongoing basis.

Liquidity controls

Evidence liquidity management tools, stress testing, and redemption policy controls for open-ended structures.

Board reporting

Produce exception logs, remediation notes, and board-ready compliance packs each period.

AEGIS converts fragmented loan data, fund documents, and policy rules into a structured compliance monitoring layer.

Join design partner programme →

The Problem

Today, compliance evidence is scattered across documents, spreadsheets, and service providers

Before AEGIS

  • Loan agreements sit in PDFs.
  • Portfolio exposures live in Excel.
  • Fund rules are buried in PPMs, policies, and legal memos.
  • Board packs are manually assembled.
  • Exceptions are discovered late.
  • Audit trails are incomplete.

After AEGIS

  • 1Upload loan book, fund documents, and policy rules.
  • 2AEGIS extracts key obligations and exposures.
  • 3The platform flags potential breaches and missing evidence.
  • 4Compliance teams review, approve, and export a board-ready report.

Every output is source-linked, timestamped, and reviewable by the fund team.

AEGIS helps teams monitor key AIFMD II loan-origination obligations, identify exceptions, and generate reviewable compliance evidence - giving fund teams one place to monitor, evidence, and report the controls that matter.

Platform Preview

One workflow first: continuous AIFMD II monitoring

AEGIS starts with the highest-urgency workflow - helping AIFMs evidence compliance with the AIFMD II loan-origination regime. Upload the loan book, fund documents, and relevant policies. AEGIS maps key obligations, checks exposures, flags potential exceptions, and generates board-ready outputs for review.

AIFMD II Compliance Engine - Q2 2026

Annex IV Filing

Due 30 Jul

on track

Risk Retention

5.0%

compliant

Single Obligor

10.0% max

fund limit · reg. 20%

monitor

Borrower Count

23 / min 10

compliant
Art. 15 Loan Origination Checklist
5% retention on all originated loans
Open-ended fund: max 20% per obligor
Liquidity management policy documented
Leverage limit set by NCA communicated
Maturity mismatch tools activated

AEGIS Advisory

Maturity mismatch tools not yet activated. Under Art. 15(4), open-ended loan origination AIFs must implement liquidity management tools. Recommend activating redemption gates before next filing.

Phase 1 - live. Continuous Art. 15 monitoring: every obligation tracked, exceptions flagged, evidence generated for review.

How AEGIS Decides

Rules decide. AI reads. Humans sign off.

A compliance product cannot be allowed to guess a limit. AEGIS separates the three jobs so each is done by the right tool and every result is traceable back to its source.

Decides compliance status

Deterministic rule engine

Every AIFMD II limit - risk retention, single-obligor concentration, leverage, borrower count, liquidity tool coverage - is a coded check with an explicit threshold. Same input, same answer, every time.

Reads documents

Language models

Used only to extract obligations and figures from loan agreements, PPMs and policies, and to draft remediation notes. Never used to determine whether a limit is breached.

Approves evidence

Human review

Every exception and every board output is source-linked to the originating clause, timestamped, and released only after named sign-off by the fund team.

Client data is never used to train models
Processing and storage in the EU (Frankfurt)
Full audit trail on every check and sign-off
Nothing AEGIS produces is legal or investment advice

Product Roadmap

Built for private credit
fund operations teams.

AEGIS starts with AIFMD II compliance and expands across the full private credit fund lifecycle - covering the workflows that matter most to AIFMs, compliance teams, and fund CFOs.

Phase 1
Completed

AIFMD II Compliance Engine

The beachhead product

Continuous monitoring of loan-originating AIF controls, exception reporting, and board-ready compliance evidence for AIFMs operating under the AIFMD II loan-origination regime.

  • Risk retention, concentration, and leverage monitoring
  • Exception detection and remediation notes
  • Board-ready compliance evidence packs
  • Liquidity management tool controls
  • Annex IV reporting support
Phase 2
Now Building

Private Credit Portfolio Controls

Deeper fund intelligence

Covenant tracking, borrower metrics, exposure movements, valuation support, and pre-deal impact analysis - connected to the same fund data layer.

  • Covenant monitoring and breach prediction
  • Borrower financial metrics and ICR tracking
  • Exposure movement and concentration alerts
  • Pre-deal AIFMD II impact simulation
  • Valuation support and IFRS 9 tracking
Phase 3
Q4 2026

Fund Reporting Layer

From weeks to one click

Recurring board packs, LP reporting support, Annex IV workflows, audit evidence, and depositary-ready workpapers - generated from live portfolio data.

  • Quarterly LP reports and board packs
  • Annex IV and regulatory reporting workflows
  • Audit and depositary workpapers
  • SFDR and ESG disclosure support
  • NAV validation and reconciliation
Phase 4
2027

Private Credit Operating System

A live control and intelligence layer

A live intelligence layer across the private credit fund lifecycle - covering every control, every obligation, and every stakeholder workflow from origination to exit.

  • Natural language queries across the fund
  • Full scenario analysis and stress testing
  • Regulatory Digital Twin for any what-if question
  • Cross-fund intelligence and benchmarking
  • Integrated AIFM operating system

AEGIS

Join the
Design Partner Programme

We are selecting 5–7 European AIFMs and private credit teams to help shape the first AIFMD II compliance engine for loan-originating funds.

Access to the live AIFMD II rule engine
Ability to prioritise the Phase 2 portfolio controls
Private product workshops with the founders
Founding pricing - locked for 36 months

Get in touch

Leave your details and we will reach out within 48 hours.