When Do You Really Need an EU Fund?

For many fund managers, conversations about raising capital in Europe often begin with a single assumption:

"We need a European fund."

Sometimes that assumption is correct.

Luxembourg has established itself as Europe's leading cross-border fund domicile and remains the preferred choice for many strategies seeking broad institutional distribution across multiple EU markets.

However, not every fundraising strategy requires a fully passported EU structure.

Recent research among allocators, advisers and fund structuring professionals highlighted a surprising finding: awareness of National Private Placement Regimes (NPPRs) remains relatively low, despite their long-established role in facilitating fundraising across parts of Europe. Several respondents admitted they had limited familiarity with NPPR, while others felt the industry has not done enough to explain where it can be an effective solution. 

This matters because fundraising strategies have changed.

Today's alternative fund managers are often targeting specific groups of professional investors rather than broad retail distribution. Family offices, institutional investors and specialist capital pools frequently have very different access requirements.

Rather than selecting a domicile first, managers should begin with a more fundamental question: what access do we actually need?

The most effective approach is to assess the investor base, target jurisdictions and fundraising objectives before evaluating structuring options.

This is where Jersey often enters the conversation.

The Island has built a strong reputation as a specialist jurisdiction for alternative assets. Its appeal lies in combining regulatory credibility with flexibility, speed to market and a pragmatic approach to fund structuring. 

Importantly, this is not a Jersey-versus-Luxembourg discussion.

Both jurisdictions play an important role in the market. Luxembourg remains the right solution for many strategies. Jersey may be more appropriate for others, particularly where managers are targeting professional investors and do not require the additional complexity of a fully passported EU structure.

The challenge is that many managers never reach that assessment stage. Instead, they default to a familiar answer before exploring alternative routes.

As fundraising environments become more competitive and cost pressures increase, domicile decisions deserve a more strategic evaluation. For some managers, that process will still lead to Luxembourg. For others, the answer may be different.

The key is ensuring the decision reflects the needs of the fund, not simply market convention.

How Belasko can help

Belasko works with fund managers across multiple jurisdictions, including Jersey and Luxembourg, helping clients evaluate and implement structures that support their fundraising, operational and regulatory objectives.

Our role is to help managers identify the most effective solution for their strategy, investor profile and long-term growth plans.

If you're reviewing fund structuring options or planning your next capital raise, Matt Devine-Hill (Head of Funds, Jersey) would be happy to discuss the considerations shaping today's domicile decisions.

Sources:

• Jersey in the Eyes of European Allocators, August 2025
• Time to Win report, March 2026
• JFA Market Positioning Jersey Funds, June 2026