New CSSF guidance on shareholding structure assessments for Luxembourg IFMs
17 Apr 2026
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On 2 March 2026, the Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial regulator, published a guidance document outlining the documents and information to be submitted for the assessment of the shareholding structure of authorised Investment Fund Managers (IFMs). The guidance applies to both initial authorisation applications and modifications to the shareholding structure of authorised IFMs and covers both qualified and non-qualified shareholders.
Key points
- The guidance specifies the minimum documentation needed for CSSF evaluations.
- Applications missing these requirements will be deemed incomplete, delaying the review process.
- The CSSF may request additional information if necessary.
Practical implications
IFMs planning on seeking authorisation or implementing changes to their shareholding structure should ensure that the documentation required by the guidance is prepared and submitted at an early stage. It is important to note that the CSSF will not begin its review until a complete submission has been received, so failure to include the specified information may result in the application being treated as incomplete and may significantly delay the overall authorisation or modification process.
This guidance aims to streamline the submission process and ensure compliance. The document is available in English and can be found here
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