On 27 June 2025, the Commission de Surveillance du Secteur Financier (CSSF) issued Circular 25/894, repealing and replacing the long-standing Circular 15/612. The previous circular had become a day-to-day tool for Luxembourg AIFMs registering new alternative investment funds (AIFs) that they manage. The new circular introduces a significantly broader framework and expanded notification obligations for Luxembourg investment fund managers (IFMs) managing funds not authorised by the CSSF.

A broader scope of notification

Circular 25/894 reflects the CSSF’s objective to maintain a comprehensive and up-to-date overview of all investment funds—regulated or not—managed by Luxembourg-based IFMs. It expands the notification requirement beyond the previous regime to include:

  • European UCITS not established in Luxembourg;

  • European AIFs, whether authorised in their home jurisdiction or not;

  • Non-authorised AIFs established in Luxembourg; and

  • AIFs established in a third country, whether authorised or not.

Where such funds comprise multiple compartments, the notification obligation applies at the level of each new compartment.

Entities in scope

The circular applies to the following Luxembourg IFMs:

  • Authorised AIFMs (within the meaning of Article 5 of the 2013 Law);

  • Registered AIFMs (within the meaning of Article 3 of the 2013 Law); and

  • UCITS management companies subject to Chapter 15 of the UCI Law (ManCos).

Notification requirements and timing

IFMs must notify the CSSF of each investment fund not authorised by the CSSF that they undertake to manage, using the dedicated eDesk procedure and the official form available on the CSSF website.

Notification deadlines are as follows:

  • Before management begins: for authorised AIFMs and ManCos;

  • Within 10 working days of commencing management: for registered AIFMs.

The CSSF considers an IFM to assume the role of manager at the latest upon:

  • The signing or effective date of the management agreement;

  • The establishment of the fund, where the IFM also acts as managing general partner or shareholder; or

  • Any other situation demonstrating that general responsibility for management has been legally and factually conferred.

Additional data requirements

In addition to fund-level information, IFMs must provide the CSSF with details regarding:

  • UCI administrator(s); and

  • Portfolio management delegate(s), and where applicable, sub-delegate(s).

Each IFM remains responsible for ensuring that the organisation, delegation, and sub-delegation structure of such funds complies with the regulations applicable to IFMs and funds not authorised by the CSSF.

Changes and cessation of management

Any material changes to submitted information, or the cessation of management, must be reported to the CSSF via eDesk:

  • Without delay in the case of changes;

  • Within 10 working days in the case of termination of the management mandate.

Immediate entry into force

Circular 25/894 entered into force on 27 June 2025 and repealed Circular 15/612 with immediate effect. No transitional measures were introduced.

A corresponding FAQ has also been published by the CSSF and is available here.

Need assistance?

For further guidance or support in adapting your internal compliance procedures to Circular 25/894, please contact our Investment Management team.