VRC and Dechert LLP have partnered to produce a three-part series examining how regulation has shaped private credit fund structures on both sides of the Atlantic. The first article focused on the evolution of fund structures, and the second article explored global valuation frameworks and oversight.

Part 3 compares the private credit regulatory frameworks in the U.S. and Europe. While the U.S. developed a wide range of scalable private credit fund structures earlier, Europe’s implementation of AIFMD 2.0 marks a significant transition toward a more unified, prescriptive, and asset-class-specific regulatory framework.

As private credit continues to expand across jurisdictions and investor segments, regulatory frameworks will remain central to the market’s long-term resilience.

For U.S. firms evaluating or acquiring EU managers and for European managers scaling globally, these distinctions directly affect how funds operate, report, and withstand regulatory scrutiny.