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CSSF updates crypto-asset guidelines: Key changes for investment funds

16 Feb 2026
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On 4 February 2025, the Luxembourg’s Commission de Surveillance du Secteur Financier (CSSF) updated its FAQs on crypto-assets, reflecting significant regulatory changes and providing guidance for various stakeholders.

Updated terminology and scope:

  • The term "virtual assets" has been replaced with "crypto-assets" in alignment with the EU Regulation 2023/1114 on Markets in Crypto-Assets (MiCAR).

Investment guidelines:

  • UCITS(Undertakings for Collective Investment in Transferable Securities) can invest indirectly in crypto-assets, capped at 10 per cent of their Net Asset Value (NAV).
  • AIFs(Alternative Investment Funds) open to retail investors (excluding well-informed investors) are also limited to a 10 per cent NAV exposure to crypto-assets.

Licensing for AIFMs:

  • Luxembourg authorised AIF Managers (AIFMs) managing funds with crypto-asset exposure exceeding 10per cent of NAV must obtain a specific license for "Other-Other Fund-Crypto-assets."

Risk management and transparency:

  • Investment managers must assess the impact of crypto-assets on fund risk profiles, update risk management policies, and ensure transparent communication with investors.

AML/CFT compliance:

  • Enhanced due diligence is required to mitigate risks of money laundering and terrorist financing associated with crypto-assets.

Depositary services:

  • Luxembourg depositaries may act for funds investing in crypto-assets, provided they meet specific regulatory and operational requirements.

These updates emphasise the CSSF's alignment with evolving EU regulations while ensuring robust risk management and investor protection in the crypto-asset space. For detailed guidance, refer to the updated FAQs here and here.