On 18 December 2025, the CSSF published Version 6 of its FAQ relating to Circular CSSF 22/811 on UCI Administrators (“UCIA Circular”).
This updated FAQ focuses on clarifying the scope of application of the UCIA Circular and removes certain previously included questions. It does not introduce new requirements.
Key points to note
Clarification of scope (Question 2.1)
The FAQ clarifies that the UCIA Circular applies to entities listed under point 2.1 of the UCIA Circular that effectively perform, in Luxembourg, one or more UCI administration functions. In addition, it now expressly states that the UCIA Circular also applies to management companies subject to Chapter 15 or Chapter 16 of the 2010 Law and to alternative investment fund managers authorised under Chapter 2 of the 2013 Law, where such entities pursue the activity of UCI administrator through a branch established in another EU Member State.
The FAQ also reiterates that entities not listed under point 2.1 of the UCIA Circular remain outside scope, including cases where the administration of an unregulated UCI is performed by the UCI itself or by its registered AIFM subject to Article 3(2) of the AIFM Law.
Deletion of FAQ questions (Questions 5.1 and 6.1)
The updated FAQ deletes former Question 5.1 on annual reporting under the UCIA Circular and former Question 6.1 on the notion of central administration. These questions are no longer covered in the FAQ. The annual reporting framework is addressed in a separate article dedicated to Circular CSSF 25/900.
BSP remains available to assist with any questions relating to the interpretation and application of the UCIA Circular and the updated FAQ.
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