Answer provided by the European Commission

“Full or partial matching of transfer requests of units or shares of the ELTIF by exiting investors with transfer requests by potential investors” within the meaning of Article 19(2a) of the ELTIF Regulation solely involves the transfer of units or shares of an ELTIF by an exiting investor to a new investor. As a result of this transfer, and unlike in the case of redemptions where the units or shares of a redeeming investor are extinguished, no new units or shares are extinguished (or created) and the number of units or shares remains the same as prior to the transfer (matching). To the extent that the volume of possible matching is limited by the volume of subscriptions, there is no impact on the unit or share count or on the portfolio of the ELTIF. As a result, the transfer of requests (matching) under Article 19(2a) does not result in or have a dilution effect. Thus, there should be no need for anti-dilution levies. 
However, to the extent that subscriptions/redemptions are processed on a matching date (whether separately or concurrently with/in addition to the matching process), in line with Article 5(9) of Commission Delegated Regulation (EU) 2024/2759, the manager of an ELTIF may, at its discretion, apply an anti-dilution levy to the additional subscriptions/redemptions that may take place. 
Moreover, irrespective of whether subscriptions/redemptions are being processed separately or concurrently with the matching of requests in accordance with Article 19(2a), an ELTIF should also be permitted to apply fees, costs and charges, if any, related to the transfer process (other than for anti-dilution purposes) as referred to in Article 19(2a)(a)(vii) of the ELTIF Regulation.

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The answers clarify provisions already contained in the applicable legislation. They do not extend in any way the rights and obligations deriving from such legislation nor do they introduce any additional requirements for the concerned operators and competent authorities. The answers are merely intended to assist natural or legal persons, including competent authorities and Union institutions and bodies in clarifying the application or implementation of the relevant legal provisions. Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. The views expressed in the internal Commission Decision cannot prejudge the position that the European Commission might take before the Union and national courts.