Evergreen Funds: Semi-liquid funds and the evolution of evergreen platforms in Luxembourg

By John Russell for Belasko, July 12 2026
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Next in our evergreen fund series we move to Luxembourg, where evergreen structures are scaling rapidly, particularly across private credit and income strategies.

The growth of evergreen funds in Luxembourg is increasingly being shaped by a broader structural shift: the rise of semi-liquid fund models.

Across private markets, asset managers are moving away from traditional closed-ended formats towards structures that combine long-term investment exposure with periodic liquidity. Semi-liquid funds sit at the centre of this transition, enabling access to private assets while offering scheduled redemption windows alongside continuous capital deployment.

This evolution is reflected in the data. As of February 2026, Luxembourg is home to 142 evergreen fund structures, reinforcing its position as the leading European hub for these vehicles. Much of this growth has been driven by the continued development of the ELTIF regime.

At its core, this shift signals a change in investor expectations. Capital is no longer exclusively institutional and long-term in nature; it is increasingly sourced from a broader investor base, where liquidity, transparency and accessibility play a more prominent role.

From closed-ended funds to continuous capital models

Traditional private market funds operate through defined fundraising cycles, with capital drawn down and deployed over time. While effective for institutional investors, this model introduces friction for a broader investor base, particularly those seeking more immediate exposure and defined liquidity terms.

Semi-liquid and evergreen structures address these constraints by enabling:

  • Continuous fundraising rather than discrete vintages
  • Immediate deployment into a live portfolio
  • Periodic liquidity through structured redemption mechanisms

This allows managers to move beyond individual funds and towards building ongoing investment platforms, where capital can be raised, deployed and recycled over time.

ELTIF 2.0 and the scaling of semi-liquid structures

The transformation of the European Long-Term Investment Fund (ELTIF) framework has been central to Luxembourg’s positioning, accelerating the shift towards semi-liquid and evergreen fund models.

The revised ELTIF 2.0 regime has made it significantly easier to structure these strategies by lowering minimum investment thresholds, broadening the range of eligible assets, and introducing more flexible redemption features within defined liquidity parameters. Together, these changes make ELTIFs far more compatible with semi-liquid structures.

Crucially, ELTIFs benefit from an EU passport, enabling funds to be marketed across multiple jurisdictions under a single regulatory framework. For evergreen funds, which rely on continuous fundraising, this ability to access investors across borders is a key enabler.

More broadly, ELTIF 2.0 has created a viable route for asset managers to reach a wider investor base. Industry commentary increasingly points to semi-liquid ELTIFs as a core mechanism for expanding private markets beyond institutional capital and into high-net-worth and private banking segments.

Private credit as a natural fit for evergreen structures

While semi-liquid structures can be applied across asset classes, their adoption has been particularly strong in private credit and income-focused strategies.

These strategies are well suited to semi-liquid formats due to:

  • predictable cash flows
  • recurring income generation
  • diversified portfolios

This allows managers to align liquidity profiles with underlying asset behaviour, supporting periodic redemptions without undermining long-term investment objectives.

As a result, private credit has become a natural entry point for managers building evergreen, semi-liquid platforms.

Operational complexity behind semi-liquid models

While the concept of semi-liquid funds is straightforward, the operational reality is materially more complex.

Three areas consistently emerge across industry discussions:

Valuation

Private assets require judgement-based pricing and must be valued more frequently to support subscriptions and redemptions. This places greater emphasis on governance, independence and valuation frameworks.

Liquidity management

Managers must carefully balance redemption requests with underlying portfolio liquidity. This is typically managed through a combination of:

  • notice periods
  • redemption gates
  • liquidity buffers or liquid sleeves

Liquidity in these structures is therefore actively managed rather than fully provided.

Operating model design

Semi-liquid funds require more sophisticated operating models than traditional closed-ended funds, including:

  • continuous investor servicing
  • more complex transfer agency and dealing cycles
  • enhanced reporting and transparency

This increases the importance of a robust servicing ecosystem capable of operating these structures at scale.

Luxembourg’s role in enabling semi-liquid platforms

Luxembourg’s position in this market is not simply a function of regulation, but of infrastructure.

The jurisdiction combines:

  • flexible fund structuring frameworks, including ELTIF
  • established AIFM, administration and depositary capabilities
  • deep cross-border distribution networks

This allows managers not only to structure semi-liquid funds, but to operate and scale them effectively.

As semi-liquid strategies evolve from niche structures into mainstream distribution tools, this ability to manage continuous capital flows within a consistent regulatory framework becomes increasingly important.

From product to platform

The emergence of semi-liquid funds reflects a broader shift in private markets investing. For asset managers, these structures offer a way to:

  • Access new investor segments
  • Create more flexible capital formation models
  • Build scalable, repeatable investment platforms

At the same time, they introduce new operational and governance requirements, particularly around valuation, liquidity and investor servicing.

Luxembourg’s role is to provide the framework and infrastructure to support this transition.

In that context, semi-liquid evergreen structures are not simply a structural innovation, but a mechanism through which private markets are being adapted to a broader and more diverse investor base.

How Belasko can help

At Belasko, we support asset managers in designing and operating scalable evergreen and semi-liquid structures, from initial structuring through to ongoing administration and investor servicing. With experience across the Luxembourg ecosystem, including ELTIF frameworks and cross-border distribution, we help clients build robust, efficient operating models that can support continuous capital flows with confidence.

Get in touch with us to discuss how Luxembourg could support your approach.

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