CSSF extends the “LMT activation” module to redemption-only suspensions

On 18 September 2026, the Commission de Surveillance du Secteur Financier (the “CSSF”) announced an extension of its eDesk “LMT activation” module to cover the activation and deactivation of suspensions of redemptions only.

The extension applies, as from 21 September 2026, under the national law provisions applicable to Luxembourg-domiciled funds subject to the Law of 17 December 2010 relating to undertakings for collective investment, specialised investment funds (“SIFs”) governed by the Law of 13 February 2007 and investment companies in risk capital (“SICARs”) governed by the Law of 15 June 2004.

The communication is particularly relevant in the context of Part II UCIs, SIFs and SICARs, for which the CSSF also reiterates certain notification requirements where they fall outside the management of a Luxembourg-domiciled authorised AIFM or, in the case of SIFs and SICARs, do not qualify as AIFs.

Importantly, the CSSF expressly clarifies that a suspension of redemptions only, without a suspension of subscriptions, does not qualify as a liquidity management tool (“LMT”) under the Law of 3 March 2026 (the “2026 Law”). Its inclusion in the “LMT activation” module is intended to simplify the notification process.

What changes from 21 September 2026?

From 21 September 2026, the activation and deactivation of a suspension of redemptions only must be notified through the CSSF’s eDesk “LMT activation” module for the Luxembourg-domiciled funds concerned.

This represents an extension of the notification framework implemented earlier this year following the adoption of the 2026 Law, which transposed Directive (EU) 2024/927 (“AIFMD II”/“UCITS VI”) into Luxembourg law.

The use of the “LMT activation” module for redemption-only suspensions should not, however, be confused with their legal qualification: the CSSF expressly states that a suspension of redemptions only does not constitute an LMT under the 2026 Law.

Specific considerations for Part II UCIs, SIFs and SICARs

The CSSF also reiterates the notification requirements applicable to:

• Luxembourg-domiciled Part II UCIs which are not managed by a Luxembourg-domiciled authorised AIFM; and
• Luxembourg-domiciled SIFs and SICARs which do not qualify as AIFs or are not managed by a Luxembourg-domiciled authorised AIFM.

According to the CSSF communication, these funds must also notify through the “LMT activation” module the activation or deactivation of suspensions of subscriptions, repurchases and redemptions, as well as the creation of side pockets previously approved by the CSSF, as required under their respective sectoral laws.

This reminder is relevant because the applicable notification requirements are not limited to funds falling within the LMT framework introduced by the 2026 Law.

Existing administrative requirements remain unchanged

The extension of the eDesk procedure does not alter the existing administrative requirements.

In particular, the CSSF confirms that supporting documentation must continue to be submitted through the usual communication channels. Market participants should therefore ensure that use of the “LMT activation” module is integrated into their existing procedures without treating the eDesk notification as replacing any supporting documentation required by the CSSF.

Key takeaway

In-scope market participants should ensure that their internal procedures reflect the new notification arrangements from 21 September 2026.

Particular attention should be given to the position of Part II UCIs, SIFs and SICARs, including structures that do not qualify as AIFs or are not managed by a Luxembourg-domiciled authorised AIFM, and to the distinction between a redemption-only suspension and an LMT under the 2026 Law.

The CSSF communication of 18 September 2026 is available here.

For further information on the matters covered in this update, please feel free to contact our Investment Management team.

This publication is intended for general information purposes only and does not constitute legal advice.