A valuation of private assets available every day. This is one of the changes Apollo Global Management aims to bring to the credit market.

When the US asset manager announced its second-quarter results on 4 August, Marc Rowan, its CEO, highlighted an initiative launched a few weeks earlier. Since 1 July 2026, Apollo produces a daily estimate of the net asset value (NAV) for its entire “investment-grade fixed income” range. The group plans to switch to daily valuation for all its credit assets from 1 October

Apollo is stepping up its daily valuation efforts

This move is significant coming from Apollo, one of the world’s leading alternative asset managers, with assets under management exceeding $1,000bn. In particular, the group has become a major player in the credit market and is simultaneously seeking to broaden access to private markets for new categories of investors.

Apollo also presents daily valuation as a means of improving transparency in private markets and making these assets more accessible to institutional investors, traditional asset managers and retail investors alike. This ambition resonates particularly strongly in Luxembourg.

Eight evergreen products in Luxembourg

The US group is already using the financial centre as a platform to develop its offering for high-net-worth clients. In September 2025, Apollo had obtained regulatory approval for three new evergreen and semi-liquid Eltifs: a European private credit vehicle, a diversified credit fund and a fund investing in private markets.

With these launches, its Global Wealth division was set to offer eight Luxembourg-based evergreen products, available for distribution in Europe, Asia and Latin America, amongst other regions.

Apollo is by no means the only asset manager seeking to make private assets more accessible to high-net-worth clients. Evergreen and semi-liquid vehicles, in particular, allow for regular subscriptions and, depending on the product, periodic redemption opportunities.

This development brings the investor’s experience closer to that offered by traditional funds. But it also highlights a fundamental contradiction.

Generating value every day does not mean being able to sell every day

A private loan, a property, a piece of infrastructure or a stake in an unlisted company does not become more liquid simply because its value is calculated on a daily basis. The frequency with which a portfolio is valued and the ability to sell its assets are two different things.

A fund may therefore publish its NAV frequently whilst only offering monthly or quarterly redemption opportunities, which may be subject to limits. In normal circumstances, these mechanisms make it possible to balance redemption requests with the liquidity available in the portfolio.

The situation becomes more complicated when a large number of investors wish to exit at the same time. It is precisely at this point that liquidity management tools come into their own.

New rules in Luxembourg since April

The timetable is of particular interest to the financial centre. The Luxembourg Act of 3 March 2026 transposing AIFMD II introduced new requirements for AIFMs authorised in Luxembourg that manage open-ended alternative funds. Since 16 April, they have been required, in particular, to select at least two liquidity management tools (LMTs) from among those provided for by the legislation. The choice of these tools, as well as the detailed policies and procedures governing their activation and deactivation, had to be notified to the CSSF.

The range includes various mechanisms. Some directly affect exit options, such as redemption gates, extended notice periods or redemptions in kind. Others, such as swing pricing, redemption fees or anti-dilution levies, are designed in particular to shift the cost of liquidity onto investors who carry out transactions rather than those who remain in the fund.

Suspensions of subscriptions and redemptions, as well as side pockets, remain tools intended for exceptional circumstances. The CSSF also asks fund managers to take into account factors such as the investment strategy, redemption terms, liquidity profile, stress test results, investor base and distribution policy when determining the appropriate tools.

A transition period until April 2027

However, there is an important caveat to the regulatory timetable. The obligations introduced into Luxembourg legislation regarding the selection and notification of LMTs have applied since 16 April 2026. However, the Esma guidelines incorporated into CSSF Circular 26/910 provide for a transitional period for funds that already existed prior to that date: they will only apply to such funds from 16 April 2027.

The transition is therefore still ongoing for part of the industry. These guidelines go beyond simply choosing between two tools. They place the responsibility for their selection, calibration and activation on fund managers. In particular, they must be able to demonstrate to the CSSF that the mechanisms chosen are suited to the fund’s characteristics and are effective both under normal conditions and in stressed market conditions.

The real test will come when people start redeeming their investments

The issue therefore goes beyond regulatory compliance. The more fund managers develop evergreen or semi-liquid funds investing in private assets, the more they must reconcile two different timeframes: that of investors, who may request to withdraw their money, and that of the assets, which cannot necessarily be sold off quickly. Liquidity mechanisms are designed precisely to manage this discrepancy.

The real test would come during a period characterised by a combination of significant redemption requests, a slowdown in new subscriptions and less favourable conditions for selling the underlying assets. Fund managers might then have to limit or defer certain redemptions, pass on a greater share of the cost to investors withdrawing their funds or, in the most exceptional circumstances, suspend redemptions.

The strategy unveiled by Apollo makes this distinction even more apparent. Daily valuation can bring private assets closer to the standards investors are accustomed to on listed markets. However, it does not alter their liquidity.

AIFMD II does not eliminate this time lag. Instead, it requires managers of open-ended funds to plan more effectively for how they will manage it when investors wish to exit.