Background
On 27 June 2025, the new circular Circular CSSF 25/894 – Information to be submitted to the CSSF in relation to investment funds non-authorised by the CSSF (the “Circular”) entered into force. The Circular focuses on transparency, risk assessment, and oversight of investment funds that operate without direct CSSF authorisation but still impact the Luxembourg financial market.
Notably the Circular repeals the Circular CSSF 15/612 published on 5 May 2015.
Key Points of Circular 25/894
Scope of Applicability
The Circular applies broadly to all Luxembourg Investment Fund Managers (IFMs) that manage a fund that is not authorised by the CSSF, setting out information that must be reported to the CSSF regarding the funds they manage.
Information Submission Requirements
Entities must submit comprehensive data covering fund identification, investment strategy, risk profile, marketing practices, and details about the fund manager. This is critical for transparency and risk management.
Furthermore, if applicable, the IFM should indicate additional service providers of the fund such as the UCI administrator(s) and portfolio management delegate(s) and sub-delegate(s).
Submission Process
All information must be submitted electronically through the CSSF’s dedicated portal. Accuracy and completeness are essential when filling out the forms. The forms required to be filled out and submitted are available here.
Regulatory Importance
Compliance with the Circular allows the CSSF to fulfil its duty of communicating to the ESMA all AIFs managed by Luxembourg AIFMs the CSSF will actively monitor adherence to these requirements.
Next Steps
Next step for IFMs after the introduction of this Circular will be to check fund portfolios and identify any investment funds not authorised by the CSSF, and to subsequently submit the required information to the CSSF within the defined time frame. In relation to authorised funds that have already been reported on, no new action is required unless there has been a substantial change to the information already submitted.
Additional Information
A FAQ (only in French) has been published by the CSSF in order to provide additional information on the implementation of the new Circular 25/894 and the repealing of Circular 15/612. The FAQ is available here.
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