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