Go to content
${facet.Name} (${facet.TotalResults})
${item.Icon}
${ item.ShortDescription }
${ item.SearchLabel?.ViewModel?.Label }
See all results
${facet.Name} (${facet.TotalResults})
${item.Icon}
${ item.ShortDescription }
${ item.SearchLabel?.ViewModel?.Label }
See all results

CSSF’s Circular 25/894: Reporting obligations for Luxembourg fund managers

16 Jul 2025
|

On 27 June 2025, Luxembourg's Commission de Surveillance du Secteur Financier (CSSF) published Circular 25/894, which establishes the obligations for Luxembourg Investment Fund Managers (IFMs) managing investment funds not authorised by the CSSF to provide information in respect of such funds via the completion of specific forms. This circular, effective immediately, repeals Circular CSSF 15/612 and applies to management companies subject to Chapter 15 of the UCI Law (ManCo15), registered AIFMs and authorised AIFMs.

Key provisions include:

Information submission: IFMs are required to submit specific forms via the CSSF eDesk for each non-CSSF authorised fund they manage. Any updates or changes to the submitted information must be reported without delay.

Deadlines:

  • ManCo15 and authorised AIFMs must provide the required information before managing a European UCITS or additional AIF.
  • Registered AIFMs must submit the information within 10 working days of managing an additional AIF.
  • Termination of management mandates must be reported within 10 working days.

IFMs bear full responsibility for ensuring compliance with applicable regulations for non-authorised funds, including their delegation and sub-delegation structures.

With respect to AIFMs, this includes AIFs established in a third country, regardless of whether they are authorised in their home country.

The CSSF requires a comprehensive and up-to-date overview of all funds managed by Luxembourg IFMs to fulfil its supervisory duties and meet the European Securities and Markets Authority (ESMA) reporting requirements.

CSSF’s Circular 25/894 can be found here.

The CSSF has published FAQ in respect of Circular 25/894, which can be found here (only in French) here.