Luxembourg may be leading the charge in Eltif launches under the revised framework, but elsewhere in the Benelux they are proving a tougher nut to crack.
While dozens of new Eltifs have been authorised in recent months—many of them domiciled in Luxembourg—the latest figures from the regulators in Belgium and the Netherlands reveal a stark contrast: not a single Belgian manager has filed for an Eltif, and only one Dutch firm has stepped forward.
That firm is Carbon Equity, an Amsterdam-based fund-of-funds specialist with a strong focus on climate investing. It has filed a single Eltif application with Dutch financial supervisor AFM, marking the Netherlands’ only home-grown attempt so far to enter the Eltif 2.0 arena.
Despite its solitary status, the move is worth watching—also for Eltif advocates and service providers in Luxembourg. Carbon Equity’s case offers a window into how next-generation Eltifs could use the Netherlands to reach high-net-worth retail audiences in markets where private equity remains largely the preserve of institutions.
Climate impact, with a retail twist
Carbon Equity aims to open access to private climate funds for individual investors from 20,000 euros—far below the 100,000-euro minimum in its existing funds. Through its Eltif, it intends to blend exposure to green infrastructure and climate tech, leveraging its existing portfolios that already manage around 300 million euros.
According to CEO Jacqueline van den Ende, the Eltif format is central to Carbon Equity’s strategy of democratising access to private markets.
“We see the fund-of-funds structure as the most logical and secure way for individuals to access impact-focused private equity,” she told Investment Officer. “It enables direct, diversified exposure to private climate innovation.”
The portfolio will include European themes such as decarbonised cement, green steel, and giga-batteries—exactly the kind of underlying assets Eltif 2.0 was designed to accommodate.
Operational challenges, strategic investment
Carbon Equity has invested heavily in its platform to prepare for Eltif distribution, with enhanced compliance systems and upgraded liquidity management. The firm is also holding active discussions with private banks and wealth managers in both Belgium and the Netherlands—highlighting the cross-border ambitions often associated with Luxembourg-domiciled Eltifs.
But for now, the structure is being launched under Dutch regulation. That in itself is telling: it shows that asset managers in other EU countries are slowly testing the waters—albeit cautiously and on a case-by-case basis.
Lessons for Luxembourg
For Luxembourg’s asset servicing ecosystem, Carbon Equity’s initiative may seem like a minor footnote. But it reflects several important trends that are central to the Grand Duchy’s Eltif success story:
- The rise of thematic Eltifs: Carbon Equity is not targeting a generic private equity portfolio, but a very specific climate impact theme—aligning with investor demand for purpose-driven products.
- A focus on democratisation: Lower minimums and digital onboarding are expanding the addressable market. Luxembourg players may find value in partnering with firms like Carbon Equity looking for passporting opportunities.
- The challenge of local ecosystems: Even with an improved EU framework, some national markets still lack the distribution infrastructure and appetite needed to scale Eltifs. Luxembourg can be a natural hub to bridge that gap.
Van den Ende is pragmatic about the competitive landscape. She sees little room left for generalist platforms in the fund-of-funds space, but plenty of opportunity for specialised thematic players.
“Investors are looking for focused expertise,” she said. “Family offices may not need a gatekeeper to access the big names—but they do appreciate deep knowledge in complex themes like climate.”
This article was originally published in Dutch on InvestmentOfficer.nl.