133 ELTIFs Registered. Only 28 Actually Reach Real Investors.

133 ELTIFs are registered with European regulators. Roughly 28 have meaningful distribution, active subscriptions, and visibility to end investors. The other ~80% exist on paper — registered, authorized, and largely invisible.

ELTIF 2.0 was pitched as the breakthrough regulatory moment for European private markets. The reform addressed most of the structural defects of the original 2015 regime: minimum ticket removed, retail suitability simplified, cross-border passport clarified, semi-liquid features permitted. Registration activity has been brisk since the reform took effect.

And yet, the gap between registered and reachable has never been wider.

What the 28 actually look like

The distributed ELTIF universe today clusters around a few predictable shapes. Large international asset managers with captive distribution — BlackRock, Amundi, Partners Group, Schroders, Neuberger Berman — account for a disproportionate share of AUM. Private banks and wealth platforms built around them push the products through their own channels. A handful of independents have cut through with differentiated strategies, most notably in private credit and infrastructure.

Outside that cluster, the tail is long and thin. Small- and mid-sized asset managers have registered ELTIFs to signal product capability, to future-proof their distribution strategy, or to check a regulatory box for a single large LP. Many of these vehicles have raised less than €50m. Some have raised nothing at all.

Why registration ≠ distribution

Five frictions separate a registered ELTIF from an ELTIF an advisor can actually recommend:

1. Platform referencing. Getting an ELTIF onto a major wealth platform — BNP Paribas Wealth, UBS, Julius Baer, Deutsche Bank, Pictet — is a 12-to-24-month process involving due diligence, legal review, operational onboarding, and share-class structuring. Fewer than 40 ELTIFs are currently referenced on the largest 10 European wealth platforms combined.

2. Local tax and regulatory wrinkles. An ELTIF is passportable in principle. In practice, each country adds its own overlay: French life insurance eligibility rules, German tax treatment under the Investmentsteuergesetz, Italian PIR compatibility, Spanish retail distribution requirements. Without local work per country, cross-border distribution stalls.

3. Distribution economics. Independent asset managers often lack the 60-80 bps retrocession budget that private banks expect on retail-distributed private market products. Without that economic alignment, the product doesn't move.

4. Minimum viable scale. Below ~€150-200m of NAV, an ELTIF carries disproportionate operational cost, limited diversification, and dependency on individual subscriber flows. Advisors recommending small ELTIFs to clients are taking on structural risk that has nothing to do with the underlying assets.

5. Sales infrastructure. Distributing to European advisors requires local sales teams across at least France, Germany, Italy, Benelux, Iberia, and increasingly the Nordics. Non-European GPs with a single ELTIF vehicle and no Continental sales presence are effectively invisible regardless of registration status.

What this means for advisors

The registered-vs-distributed gap creates three problems for the advisor community:

Signal noise. Industry press reports ELTIF AUM growth using total registration counts. But an advisor's decision set is much narrower than the headline universe suggests. The AUM-weighted top 20 ELTIFs likely account for 75-85% of total ELTIF AUM, which is the reality the market actually operates in.

Selection bias. Because the 28 distributed ELTIFs are disproportionately products of the largest asset managers, advisors building ELTIF allocations end up concentrated in a handful of GPs. That's not inherently bad — these are the largest, most established managers in private markets — but it's worth recognizing as a structural feature rather than an active choice.

Innovation lag. Smaller GPs that might bring differentiated strategies (niche private credit, specialty infrastructure, regional real estate) struggle to get distributed. The democratization of private markets is, paradoxically, being concentrated among fewer providers than the closed-end fund universe was.

What the next wave looks like

Three shifts are visible in the pipeline:

Platform aggregation. Digital platforms are emerging to aggregate ELTIF distribution, particularly targeting independent financial advisors and IFA networks. The economics differ substantially from traditional private-bank distribution — lower retrocessions, higher throughput, standardized onboarding.

GP-led consolidation. Several mid-sized European GPs are consolidating their evergreen product shelves: rationalizing sub-scale ELTIFs, launching flagship vehicles, and investing in cross-border distribution infrastructure. The 133 number will likely shrink before it grows.

Feeder structures. Some large non-European GPs are using ELTIFs as feeder structures into their institutional evergreen flagships. This solves the retail-access problem without requiring each GP to build bespoke European retail products.

For fund managers: what distinguishes a reachable ELTIF

The characteristics of the distributed 28 point to a reproducible template:

• Backed by a GP with existing European distribution relationships
• Built with retrocession economics compatible with private-bank channels
• Targeting €300m+ NAV within the first 24 months of launch
• Supported by local sales presence in at least three major European markets
• Documented with advisor-friendly materials: fact sheets, risk summaries, suitability guidance
• Tax-optimized in the top three target markets (France, Germany, Italy)

GPs without at least four of these six should expect their ELTIFs to remain in the 105, not the 28.

The takeaway

The ELTIF reform worked. The structure is sound, the regulatory framework is credible, and institutional scale is emerging. But the distribution gap is wider than the industry acknowledges. For advisors, that means working from a narrower effective universe than the headlines suggest. For asset managers, it means that product registration is the first 20% of the job — the other 80% is distribution infrastructure that the market has not yet fully built.