Publication
The CSSF officially published Circular 25/894 (the "Circular") on 26 June 2025, setting out a broader framework and expanded notification obligations for Luxembourg investment fund managers ("IFMs") managing funds that are not authorised by the CSSF.
In principle, the Circular states that IFMs must notify the CSSF, via the eDesk portal, of:
- the funds under management, whether already established or in the process of being constituted;
- any material changes relating to these funds; and
- the cessation of management of an AIF.
For further information read our previous newsletter.
On 3 October 2025, the CSSF updated its Q&A pertaining to the Circular to provide clarifications on three specific points.
Key updates
The retroactivity of the Circular
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Deadline for submissions
- If the fund has not yet been established but the IFM has already started managing it: the information must be submitted no later than 10 working days following the fund’s establishment.
- In the event of a cessation of management: the information must be submitted to the CSSF from the date the cessation occurs and no later than 10 working days after the termination of the IFM mandate.
The FAQ set out the acceptable configurations in terms of service providers, the funds and their IFMs:
Luxembourg AIFM and AIF
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ManCo15 and European UCITS
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