From 1 April 2025, the Commission de Surveillance du Secteur Financier (CSSF) will implement a new e-Identification procedure for UCI prospectuses’/offering documents’ amendments, replacing the traditional visa stamping process. This change applies to both UCITS and non-UCITS funds (Part II UCIs, SIFs, SICARs, and ELTIFs) and introduces a centralised digital submission via the CSSF’s eDesk platform.

Under this new framework, all amendments to a fund prospectus/offering document must be filed through eDesk, whether or not they require prior CSSF review.

A short transitional period is in place:

  1. Changes submitted before 31 March 2025 and already transmitted via e-file may still follow the current visa stamping process until 16 April 2025.
  2. Submissions lacking the e-file transmission before 31 March must follow the e-Identification route.
  3. For changes that do not require prior CSSF review, the e-Identification procedure via eDesk will apply from 1 April 2025 onward. The clean version of the prospectus/offering document must be submitted directly, together with the completed eDesk form. There is nothing to submit to the CSSF via e-mail anymore.
  4. Any changes filed after 31 March 2025 which are either material or a mix of changes requiring and changes not requiring a prior review by the CSSF must be submitted first via email to the CSSF following the usual process with the track changes version of the prospectus/offering document highlighting changes requiring CSSF prior approval and then following the approval or non objection of the CSSF via the CSSF’s eDesk e-Identification application.

In all cases for 2 to 4, completion of the eDesk form is mandatory.

The e-Identification process distinguishes between material and non-material changes:

  • Material changes include updates to investment policy, fee structures, or governance arrangements. These may require prior CSSF approval, investor notification, and a one-month minimum notice period before implementation.
  • Non-material changes, such as formatting improvements, updated regulatory references, or clarifications, may be submitted directly, without CSSF review or advance notice to investors.

Material changes must not be implemented until the notification period has expired. During this time, investors must be offered the right to redeem free of charge. In some cases, the UCI may also offer conversion to another fund or sub-fund, also free of charge.

The CSSF may grant derogations from these rules in limited, well-justified cases — for instance, when all investors have consented to the change or where a shorter notice period is deemed sufficient.

Even where no prior authorisation is required, the CSSF reserves the right to request further explanations or documentation on a case-by-case basis.

Where a prospectus amendment impacts the fund’s articles of association or management regulations, the file must be submitted to the CSSF for prior review before initiating the e-Identification process. This applies even if the underlying change itself is not material under other criteria.

These new rules will positively affect timing, structuring, and investor communication — particularly for filings made around the regulatory switchover.

If you are considering changes to your fund documentation, or unsure whether your next filing requires prior approval or investor notice, please do not hesitate to contact our Investment Management team