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14 November 2025

Facilities Agents: Enabling Efficient Cross-Border Retail Distribution For Funds

MG
Maples Group

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The Maples Group is a leading service provider offering clients a comprehensive range of legal services on the laws of the British Virgin Islands, the Cayman Islands, Ireland, Jersey and Luxembourg, and is an independent provider of fiduciary, fund services, regulatory and compliance, and entity formation and management services.
When expanding into new markets, gaining traction can prove a balancing act for fund managers. Understanding operational nuances and complying with local regulations and investor requirements can add risk...
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Facilities agent services can help fund managers enter new markets, access cross-border capital and remain compliant with local regulations.

When expanding into new markets, gaining traction can prove a balancing act for fund managers. Understanding operational nuances and complying with local regulations and investor requirements can add risk, cost and time to market. Having an adviser who can navigate the rules and requirements of a new jurisdiction can make this transition a seamless one.

Facilities agent services help pave the way for fund managers to access capital across borders. Cross-jurisdictional guidance for regulation to foreign collective investment schemes ("CIS"), including Undertakings for Collective Investment in Transferable Securities ("UCITS") funds, retail alternative investment funds ("AIFs") and European long-term investment funds ("ELTIFs") can aid with various facets of establishing and maintaining distribution in a new domicile. Fund marketing, compliance and filing are among the ways a facilities agent can help fund managers operate in a new domicile.

Where facilities agent services are integrated with fund administration, fiduciary and legal advisory capabilities, managers can benefit from streamlined coordination across the fund lifecycle and reduced operational burdens.

Our Facilities Agent team at the Maples Group supports the entire fund lifecycle; from initial market entry to ongoing regulatory maintenance, ensuring that managers can access investors with confidence and efficiency.

What is a facilities agent and why is this an important service for alternative fund managers?

Facilities agents assist with supporting distribution of funds to retail investors across the EEA and can be an indispensable part of the fund manager's toolkit. They serve as a central point of contact among fund managers, investors and regulators, including on communication and documentation. Facilities agent service providers also facilitate information transfer, including procedures, payments and other investor facing arrangements.

In the EU and UK, "facilities" requirements are principally relevant where UCITS or AIFs are marketed to retail investors. Under EU law, the facilities available must cover certain investor-facing functions and documentation must be provided in the language of the host Member State or another language accepted by the competent authority. Importantly for fund managers, facilities agent services can come from a single point of contact – no matter where those investors are located. In turn, this is often more cost effective for the fund manager, reducing vendor complexity and supporting consistent oversight.

How does a facilities agent benefit fund managers and raising capital?

Facilities requirements have been harmonised at a high level across EU Member States under the cross‑border distribution framework, though local practices and expectations can differ. Any UCITS or retail distributed AIFs, including ELTIFs that are marketed to retail investors in any Member State of the EU must have facilities in place.

This setup gives investment managers access to investors and their capital across more jurisdictions, making capital raising and investor relations across jurisdictions more straightforward. It can also help demonstrate good governance and investor protection standards expected by host regulators.

What legal and regulatory considerations should fund managers keep in mind with regards to facilities agent services?

The backdrop behind facilities requirements is to extend protection to and giving greater aid to retail investors. The requirements provide for a harmonised set of documentation and investor-facing functions, including handling of investor complaints, access to fund documentation and information on how to redeem or subscribe as applicable.

In addition, the facilities agent regulation gives investors in some of those smaller jurisdictions greater access to investment opportunities, while at the same time opening a broader investor base to investment managers in a more cost-effective and less administratively burdensome manner.

One such example is the Mutual Recognition of Funds ("MRF") regime between Hong Kong and Ireland. In 2025, Hong Kong's Securities and Futures Commission ("SFC") and the Central Bank of Ireland ("CBI") agreed a memorandum of understanding (the "Memorandum") to establish a bilateral MRF framework. The updated framework provides for an expedited process for recognition of eligible investment funds in either jurisdiction, allowing for streamlined distribution across borders. Funds can be launched to the public in both jurisdictions within an approval process of 15 business days, subject to eligibility and completeness of submissions, pending regulatory standards being met.

To be marketed in Hong Kong under the Memorandum, Irish-domiciled UCITS funds must:

  • Fall under one of several specified fund types;
  • Adhere to certain investments and management rules, including not allocating to physical commodities, real estate or cryptocurrencies / crypto-assets;
  • Be managed by an Irish management company; and
  • Appoint a representative based in Hong Kong.

Funds can be launched to the public in both jurisdictions within an approval process of 15 business days, pending certain regulatory standards are met. Broadly parallel requirements apply to Hong Kong-domiciled funds seeking recognition in Ireland, including in terms of fund types and permissible asset classes; rules for distribution; and authorisation from local regulators. One notable stipulation in the Memorandum for Hong Kong funds looking to market in Ireland: the appointment of a facilities agent.

What are key considerations for fund managers looking to engage a service provider to fulfil the facilities agent role?

Expanding into new markets is rarely straightforward. Local regulations, investor requirements and operational nuances can slow entry and increase risk. A well-structured facilities solution bridges this gap by aligning regulatory requirements with practical distribution needs, allowing managers to focus on raising capital and building investor relationships.

Whether entering the EEA, the UK or other regulated markets, a facilities agent provides cross-border presence, local investor access and compliance support aligned with host expectations.
Key selection criteria typically includes geographic coverage, depth of regulatory expertise, integration with related services, responsiveness and transparency on service levels and fees.

Maples Group Capabilities

It is important to work with an established provider with a global outlook such as the Maples Group. Our cross-jurisdictional expertise and deep experience differentiate us and can add value for managers beyond the facilities function.

Our offering covers:

  • Full UCITS, ELTIF and AIF facilities agent coverage across key EEA and UK jurisdictions;
  • Local investor and regulatory access
  • Integration with fund registration, fiduciary, and compliance services; and
  • Efficient onboarding and responsive support to meet market timelines and reduce administrative burdens.

The Maples Group provides a suite of client services spanning middle- and back office, fiduciary, and regulatory and compliance and legal services. We can provide support for the entire lifecycle of a fund, from legal setup, through to regulatory and compliance services, along with full fund servicing capabilities, including AIFM or management company offerings.

Our Global Registration Services team also has extensive experience in registering funds across countries, jurisdictions, and exchanges. Our local teams are backed by an extensive global network of colleagues, which allows us to service clients across time zones and jurisdictions. We tailor solutions as regulation advances, investment strategies change, funds grow and operational requirements evolve. Get in touch with the Facilities Agent team at the Maples Group to learn more.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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