Luxembourg · Debt funds

77%

of the investors in Luxembourg debt funds are based in Europe. If your fundraising plan includes them, the vehicle is part of the plan.

European institutions buy Luxembourg paper. An Asian credit manager with a European fundraising plan and no Luxembourg vehicle is not in that room, and reverse solicitation is not a way in. Here is the map.

See the three routes → Send me your plan →

Investors in the EU77% Loans deployed in the EU73% Top 30 debt managers in Luxembourg90%+ AuM growth, 202424.7% Funds under €100m49%

The plan that rarely works

"Ask a private credit manager in Singapore or Hong Kong where fund two is coming from and the answer is Europe. Ask how, and the answer is an offshore fund and a lot of flights."

The book is good. The borrowers are good. The Asian LPs are already in. Pension funds, insurers and the large allocators in Germany, the Netherlands and France are the next room.

That room has a door, and ALFI's September 2026 debt funds brochure shows where it is. 77% of the investors in Luxembourg debt funds are based in the EU. 73% of the money is lent there. Over 90% of the world's top 30 debt managers run a Luxembourg vehicle.

It is not that a Luxembourg fund is a better fund. It is that the people who sign the subscription already know it. An SCSp or a RAIF does not need a memo to the investment committee. The depositary does not need a call with legal. Nobody has to make an exception for you, and institutions do not like making exceptions.

And it is not a market of mega funds. Half of Luxembourg's debt funds, 49%, have assets up to €100 million. It is a market of funds like yours.

Three ways into Europe

One of them scales. One of them is not a plan.

A non-EU fund can be offered in Europe. The question is whether the route holds up when a pension fund's compliance team asks who approached whom.

Route one

The passport

A Luxembourg vehicle, an SCSp or a RAIF, with an EU authorised AIFM. Marketed to professional investors in all 27 member states on one notification. The route European institutions expect, and the only one that scales with the investor list.

What it adds: an authorised AIFM, a depositary, the loan-origination rules. One notch up from the €50k fund, not ten.

Route two

Private placement, country by country

A non-EU fund offered under national private placement rules. Workable in a handful of countries, slow or effectively closed in others. Each one is its own file, its own counsel and its own clock.

Route three

Reverse solicitation

The investor must come to you, unprompted, and you must be able to prove it. ALFI's brochure puts it in a footnote: reverse solicitation is not a means of distribution in itself. It is what gets written down after the fact.

The honest comparison

What the passport replaces

The flights. The country files. The "we met at a conference" paper trail. The exception memo that every European institution would otherwise need to write about you.

Ask which route fits your list →

Reverse solicitation is not a distribution strategy. The passport is, and it costs less than the flights it replaces.

Which wrapper for which investor

The structure follows the investor list.

Not the other way round. Three investor profiles, three set-ups. Most first funds are the first or the second.

Who is on the listVehicleManagerWhat it adds

A handful of LPs who already know youSCSpRegistered AIFM, carried by the GPThe €50k fund. No passport, and none needed. See the benchmark →

European institutions: pension funds, insurers, allocatorsSCSp or RAIFThird-party authorised AIFMThe passport. A depositary, an auditor, the loan-origination rules.

Semi-professional and retail money across EuropeELTIF 2.0Authorised AIFMThe retail passport, with the diversification and liquidity rules that come with it. Relevant for a few credit strategies, not most.

From the €50k fund

One notch up. Not ten.

A debt fund built for European LPs sits above the €50k benchmark. Here is exactly what moves, and why none of it is exotic.

An authorised AIFM instead of a registered one

This is what gets you the passport. A third-party AIFM charges for the responsibility it takes on, and its fee scales with assets, which on a first fund works in your favour.

A depositary

Required once an authorised AIFM is in the picture. Your LPs' due diligence questionnaire would have asked for one anyway.

An auditor

Required on the regulated routes and expected by every institution on your list.

The loan-origination rules

AIFMD 2 has applied since 16 April 2026 and Luxembourg transposed it in March. For a fund that originates loans: a cap per financial borrower, leverage limits, retention on loans you sell on, closed-ended by default, no consumer loans in Luxembourg. Whether and how the rules reach a registered sub-threshold manager is a question for counsel, and we ask it before anyone signs.

20%

of capital, the most you can lend to any single borrower that is a financial undertaking, an AIF or a UCITS.

175% / 300%

of NAV, the leverage cap for an open-ended and a closed-ended loan-originating fund respectively.

of the notional retained on any loan you originate and sell on. Funds set up before 15 April 2024 have until 16 April 2029.

All of it priceable before anyone signs. Under €100 million, which is where half the market sits, the numbers are smaller than people expect.

Why Luxembourg paper

Not a better fund. A fund nobody has to explain.

Investor recognition

European pension funds, insurers and fund of funds have seen the SCSp and the RAIF a thousand times. No exception memo, no call with legal.

A settled market

80% of Luxembourg's indirectly supervised lending vehicles are SCSps. The RAIF has overtaken the SIF because it skips product approval and is supervised through its AIFM.

Loan origination, confirmed

The Luxembourg regulator has long confirmed that AIFs can originate and acquire loans. AIFMD 2 now gives that a harmonised EU framework.

No label required

71% of Luxembourg private debt funds are SFDR Article 6. Some institutions will ask for Article 8. If your strategy supports it, do the work. If not, say so and move on.

A path to scale

The same vehicle and the same providers carry you from ten LPs to a passported fund, or into an ELTIF, when the investor list demands it. You do not rebuild. You add.

Both time zones

Mangis Bay operates between Luxembourg and Singapore. Credit managers in Asia get a counterpart who is awake when they are, and who knows the AIFMs and depositaries in Luxembourg by first name.

Who this is for

Credit managers with a European fundraising plan.

Private credit managers in Singapore, Hong Kong, Malaysia, Australia, Japan and the Middle East raising from European institutions
European credit managers moving from club deals to institutional money
Family offices formalising a lending book with outside capital
Anyone whose current plan relies on reverse solicitation

How Mangis Bay fits

Not a law firm. Not an AIFM. The person who knows which ones to call.

Mangis Bay works with a select group of Luxembourg providers who are good with managers of this size and price simplicity honestly. Our job is to read your fundraising plan, tell you which wrapper and which marketing route fit the investors on it, show you the running cost line by line, and put you in front of the right AIFM, depositary, administrator and counsel in the right order. Structure, providers, banking, launch.

Every case is priced on its own terms. If your strategy needs an open-ended structure, a RAIF or an Article 8 label, the number goes up and we will show you exactly why.

Send the plan

Send the plan. Get the map.

Tell me which LP types and which countries you are targeting, and the strategy in one line. No obligation, no sales call unless you ask for one.

What you get back, within one business day

A one-page map for your plan.

Which wrapper, which marketing route, what it costs to run, and where you sit against the AIFMD 2 rules. Written by me, not a template.

The Luxembourg debt fund map.

One page with the figures, the three routes, the wrapper table and the rules. Sent with my reply.

A 20-minute call, if useful.

Once you have read my notes, you decide whether a conversation is worth your time. Nobody is chased.

Emailchristophe.santer@mangisbay.com SocialLinkedIn — Christophe Santer ↗