Situation as at 31 December 2025
BankWealth ManagerAll Firms
No description available.
Asset ManagerWealth ManagerBank
No description available.
Asset Manager
No description available.
Payment Provider
No description available.
Asset ManagerBankWealth Manager
No description available.
BankWealth ManagerAll Firms
No description available.
FintechPayment Provider
Table listing the professional activities and the mandates performed
This CSSF publication is an updated table (in XLSX format) listing standardized professional activities and mandates for members of the management body/governing body and conducting officers, as required under points 105 and 107 of Circular CSSF 18/698. It matters because it ensures consistent, transparent reporting of senior personnel roles in Luxembourg investment fund managers (IFMs), supporting governance, conflict-of-interest management, and CSSF supervisory oversight. Compliance professionals must use this list to standardize disclosures in authorization files and ongoing reporting.
What Changed
The document was originally published on 14 January 2019 and updated on 12 March 2026, reflecting revisions to the predefined list of professional activities and mandates[Source URL]. Key aspects include:
Alignment with Circular CSSF 18/698 requirements for IFMs (management companies for UCIs and AIFs), specifying reportable roles like those in collective portfolio management, risk management, valuation, compliance, internal audit, and IT operations.
Emphasis on detailed documentation of mandates to demonstrate fitness, properness, and avoidance of conflicts, including for shareholders with...
What You Need To Do
- Download and use the XLSX table
- Update authorization and notification files
- Conduct fit-and-proper assessments
- Annual compliance review
- Policy updates
Key Dates
14 January 2019 - Original publication of the list.
23 August 2018 - Publication of underlying Circular CSSF 18/698, setting baseline requirements.
End of May (post-financial year) - Compliance deadline for Circular 18/698 obligations, including governance reporting (e.g., 5 months after year-end). DEADLINE
12 March 2026 - Latest update to the list, requiring immediate review and integration into reporting processes[Source URL].
Compliance Impact
Urgency: High – The March 12, 2026 update coincides with today's date, demanding immediate review to avoid supervisory findings during CSSF inspections or authorization processes. Non-compliance risks authorization delays, fines, or reputational damage, as Circular 18/698 emphasizes robust governance in a heightened scrutiny environment for IFMs (e.g., delegate oversight, AML).
Asset ManagerBankAll Firms
Press release 26/05
Asset ManagerWealth Manager
No description available.
Asset ManagerWealth Manager
Situation as at 28 February 2026
BankAsset ManagerBroker Dealer
Situation as at 31 January 2026
Asset ManagerWealth Manager
Situation as at 31 January 2026
Asset ManagerBankWealth Manager
Administrative sanction imposed on a réviseur d’entreprises agréé
The CSSF imposed an administrative sanction on 2 December 2025 against an approved statutory auditor (*réviseur d’entreprises agréé*) for breaches of professional obligations, likely related to continuing education requirements under Luxembourg's Audit Law, mirroring patterns in recent similar cases. This enforcement action underscores the CSSF's rigorous oversight of audit professionals, emphasizing compliance with ongoing training mandates to maintain audit quality and market integrity. Compliance professionals should note it as evidence of heightened scrutiny on non-delegable professional duties.
What Changed
This is not a regulatory change or new requirement but an enforcement action applying existing rules under point f) of Article 43(1) read with point a) of Article 43(2) and Article 44 of the Law of 23 July 2016 on the audit profession (Audit Law), alongside CSSF Regulation N°16-10 on continuing education.
What You Need To Do
- Immediate self-audit
- Remediation plan
- Internal training programs
- Fit-and-proper reviews
- Record retention
Key Dates
2 December 2025 - Date of administrative sanction imposition by CSSF.
6 March 2026 - Publication date of the sanction notice (today's date, aligning with CSSF practice for transparency under Article 48(2) of the Audit Law).
31 December 2024 - Likely reference period end for continuing education non-compliance (inferred from identical prior case). DEADLINE
Compliance Impact
Urgency: Medium. This matters as a signal of CSSF's proactive controls on auditor CPE, with fines starting at EUR 1,500 for initial breaches but scaling with severity/duration; repeated actions (e.g., multiple 2025 sanctions) indicate rising enforcement tempo, risking broader audit ecosystem scrutiny. Affected parties face direct fines and reputational harm, while others must prioritize CPE to avoid chain-reaction liabilities in financial reporting.
All Firms
Administrative sanction imposed on a réviseur d’entreprises agréé
The CSSF imposed an administrative sanction on 2 December 2025 against an approved statutory auditor (*réviseur d’entreprises agréé*) for breaches of professional obligations, likely related to continuing education requirements under Luxembourg's Audit Law, mirroring patterns in recent similar cases. This enforcement action underscores the CSSF's rigorous oversight of audit professionals, emphasizing compliance with ongoing training mandates to maintain audit quality and market integrity. Compliance professionals should note it as evidence of heightened scrutiny on non-compliance with minimum continuing education hours.
What Changed
No new regulatory changes are introduced; this is an enforcement action applying existing rules under point f) of Article 43(1) read with point a) of Article 43(2) and Article 44 of the Law of 23 July 2016 concerning the audit profession (Audit Law), alongside CSSF Regulation N°16-10 on continuing education for statutory auditors. Breaches typically involve failing to meet the minimum total hours of continuing education by the reference period end (e.g., December 31, 2024, as in a comparable August 2025 case).
What You Need To Do
- Statutory auditors must immediately verify compliance with Article 3(1) of CSSF Regulation N°16-10, ensuring minimum continuing education hours are met for relevant periods
- Audit firms should conduct internal audits of training logs and implement remediation plans, including supplementary training if deficits exist
- All affected parties must report any identified breaches to CSSF proactively and retain evidence of corrective actions, as CSSF controls under Article 10 of the Audit Law can trigger fines
Key Dates
2 December 2025 - Date of administrative sanction imposition by CSSF.
6 March 2026 - Publication date of the sanction notice.
31 December 2024 - Reference period end for continuing education compliance (inferred from similar case). DEADLINE
Compliance Impact
Urgency: Medium. This matters due to the pattern of CSSF enforcement on audit continuing education (e.g., EUR 1,500 fine in August 2025 case for similar breaches), signaling ongoing supervisory controls that could expand to on-site inspections. Non-compliance risks fines, public naming (or anonymous publication per Article 48(2) Audit Law), and reputational damage, but lacks immediate firm-wide deadlines, reducing to medium urgency for proactive reviews.
All Firms
No description available.
BankWealth ManagerFintech
No description available.
BankWealth ManagerFintech
No description available.
BankWealth ManagerAll Firms
Situation from February 2025 to February 2026
BankAsset ManagerBroker Dealer
Situation from February 2025 to February 2026
BankAsset ManagerBroker Dealer
Situation from February 2025 to February 2026
Asset ManagerBankBroker Dealer
No description available.
The CSSF published guidance on 2 March 2026 specifying minimum documents and information required for assessing shareholding structures of authorised Investment Fund Managers (IFMs) during initial authorisation and subsequent modifications, covering both qualified and non-qualified shareholders. This matters because incomplete submissions will not be processed, potentially delaying authorisations or amendments amid ongoing CSSF scrutiny of governance and ownership in Luxembourg's fund sector.
What Changed
Minimum Document Requirements: Establishes a mandatory list of documents for each new shareholder candidate, differentiated by type (e.g., natural person, legal person, beneficial owner, direct/indirect qualified/unqualified shareholders, legal arrangements like trusts). Examples include identification documents (ID, CV, DH, CR), beneficial owner details (especially if PEP or CSSF-requested), and templates via Market Entry Form (MEF).
Additional Mandatory Submissions: For changes involving qualified holdings (entry, increase/decrease, removal), requires updated group structure charts, MEF (in...
What You Need To Do
- Review Guidance
- Prepare Complete Packages
- Submit Fully
- Internal Processes
Key Dates
2 March 2026 - Publication and effective date Guidance applies immediately; incomplete applications received on/after this date will not start processing until complete.
Compliance Impact
Urgency: High – Effective immediately on publication (2 March 2026), with strict non-processing of incomplete files risking significant delays in time-sensitive authorisations/amendments. Matters for maintaining operational timelines in competitive fund markets, where CSSF oversight of IFM ownership ties to broader governance expectations (e.g., board composition, qualifications).
Asset Manager
Version 1.0
This CSSF guidance (Version 1.0, published 2 March 2026) specifies the minimum documents and information required for assessing shareholding structures of authorised Investment Fund Managers (IFMs) during initial authorisation or modifications involving qualified and non-qualified shareholders. It standardises submissions to ensure completeness, with incomplete applications rejected until fully provided, enhancing regulatory efficiency and scrutiny of ownership changes. Compliance professionals must prioritise this to avoid delays in authorisation processes for Luxembourg-domiciled IFMs.
What Changed
Minimum Document Lists: Introduces detailed checklists in an XLSX format covering candidate shareholder documents (e.g., ID, CV, declarations of honour (DH), criminal records (CR) for natural persons; similar for legal persons, beneficial owners, and legal arrangements like trusts).
Differentiation by Shareholder Type: Requirements vary by natural/legal person, beneficial owner, direct/indirect qualified/unqualified shareholders, and involvement in financing (e.g., "Yes, if PEP or if requested by the CSSF" for beneficial owners; full docs for trustees in legal arrangements).
Other Mandatory...
What You Need To Do
- Prepare Complete Packages
- Submit Core Items
- Initial/Modification Filings
Key Dates
2 March 2026 - Publication and immediate applicability New guidance effective; incomplete applications received on/after this date not processed until complete.
Compliance Impact
Urgency: High – Immediate effect from 2 March 2026 means any ongoing or planned IFM authorisation/modification applications risk delays or rejection if non-compliant, potentially disrupting fund launches or ownership restructurings in Luxembourg's key investment management hub. Matters due to standardised scrutiny on fit-and-proper ownership, aligning with AIFMD governance and reducing administrative back-and-forth.
Asset Manager
Situation as of 31 December 2025
Asset ManagerBank
amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting requirements and certain corporate sustainability due diligence requirements
Asset ManagerBankWealth Manager
No description available.
BankWealth Manager
No description available.
BankWealth ManagerAll Firms
No description available.
BankWealth ManagerFintech
No description available.
Asset ManagerBank
No description available.
Asset ManagerWealth ManagerBank
Conditions relating to the organisation of the credit institution issuing covered bonds
Bank
Conditions specific to each covered bond issue programme
Bank
No description available.
BankWealth Manager
No description available.
BankWealth ManagerFintech
No description available.
The CSSF has updated its FAQ on portfolio transparency requirements for UCITS ETFs, relaxing disclosure frequency from monthly to quarterly publication of detailed holdings while maintaining daily information sharing with market makers and authorized participants. This change aligns Luxembourg's regulatory framework more closely with Ireland's semi-transparent ETF approach and is designed to attract active asset managers to the Luxembourg domicile by reducing proprietary information exposure.
What Changed
The update modifies two critical FAQ sections:
*Portfolio Transparency Requirements (Question 12.1)
The CSSF has expanded and clarified its guidance to apply to all UCITS ETFs, not just actively managed ones. The key modification establishes a two-tier disclosure framework:
Daily disclosure to market participants: Market makers and authorized participants (APs) continue to receive detailed portfolio information on a daily basis to maintain efficient arbitrage mechanisms and active secondary markets.
Quarterly public disclosure: Investment Fund Managers (IFMs) must now publish detailed...
What You Need To Do
- *For IFMs Managing UCITS ETFs
- *Update disclosure procedures to transition from monthly to quarterly publication schedules for detailed portfolio holdings
- *Maintain daily information sharing with APs and market makers to support arbitrage mechanisms—this requirement remains unchanged
- *Revise prospectuses to reflect the new quarterly disclosure frequency and confirm compliance with the 30 business-day publication window
- *Document procedures for calculating the 30 business-day deadline from quarter-end
Key Dates
17 February 2026 - CSSF publishes updated FAQ (effective immediately)
No explicit transition period stated - Firms should implement changes promptly to ensure compliance with the new quarterly disclosure requirement DEADLINE
Compliance Impact
Urgency: HIGH
Asset Manager
Version 23
This CSSF FAQ (Version 23, updated 17 February 2026) provides interpretive guidance on the Luxembourg Law of 17 December 2010 relating to undertakings for collective investment (UCIs), covering UCITS, Part II UCIs, SIFs, and SICARs. It matters for compliance professionals as it clarifies authorisation processes, investment rules, and supervisory expectations, ensuring alignment with evolving EU frameworks like AIFMD and MiCAR. The update, effective today, addresses recent regulatory shifts including crypto-asset integration.
What Changed
Authorisation Requirements: UCIs require CSSF approval of constitutive documents (articles, management regulations), depositary selection, and management company/AIFM applications for contractual forms. Corporate UCIs need similar approvals for appointed managers.
Crypto-Asset Updates (aligned with separate but related FAQ Version 7): Replaces "virtual assets" with "crypto-assets" per MiCAR (EU 2023/1114); UCITS and retail AIFs (non-well-informed investors) capped at 10% NAV indirect exposure; AIFs for well-informed/professional investors have no cap but require governance, risk management,...
What You Need To Do
- Review and Update Documents
- Crypto-Specific
- Authorisation/Amendments
- Governance and Reporting
- Ongoing Compliance
Key Dates
17 February 2026 - FAQ Version 23 update effective Applies immediately to UCI operations, authorisations, and compliance.[User-provided content] DEADLINE
04 February 2026 - Crypto FAQ Version 7 update effective MiCAR-aligned changes on crypto exposure, authorisation extensions, and depositary notifications.
16 January 2026 - UCI Authorisation page update Reflects ongoing CSSF expectations for approvals.
20 May 2025 - Related AIFM FAQ Version 24 Introduces changes relevant to UCI managers acting as AIFMs.
Compliance Impact
Urgency: High – The update coincides with MiCAR implementation and today's release, requiring immediate review for crypto-exposed funds to avoid unauthorised strategies or AML gaps; non-compliance risks supervisory actions, authorisation delays, or investor disputes in Luxembourg's key fund domicile.
Asset ManagerHedge FundAll Firms
For which the CSSF is the relevant competent authority under Regulation (EU) No 236/2012 of the European Parliament and of the Council of 14 March 2012 on short selling and certain aspects of credit default swaps
BankBroker DealerAsset Manager
Version 1
Asset ManagerBank
Version 1
Asset ManagerBank
Version 3.1
Asset ManagerBank
Version 3.1
Asset ManagerWealth Manager
No description available.
BankWealth ManagerFintech
Situation as at 31 December 2025
Asset ManagerWealth Manager
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
No description available.
BankFintechCrypto Exchange
Version 3
This CSSF FAQ (Version 2, July 2013, with updates through 24 June 2013 and 11 July 2013) provides guidance on master-feeder structures for UCITS funds under the Luxembourg Law of 12 July 2010 (the "2010 Law"), addressing financial reporting, performance disclosure, and operational requirements. It matters for Luxembourg-domiciled UCITS managers and depositaries as it clarifies compliance with UCITS Directive rules on aggregation of charges, audit irregularities, and past performance in cross-border master-feeder setups, reducing ambiguity in documentation and investor communications.
What Changed
Financial reporting for aggregate charges (Art 82(2) 2010 Law): When master and feeder UCITS have different year-ends, feeder must present master charges for the same period if possible; otherwise, use master's last audited period with strict conditions (e.g., clear audit report disclosure, no undue costs), and agreements must mandate information provision.
Disclosure of irregularities (CSSF Regulation 10-05 Art 27(e)): Present in notes to financial statements or "other information" section of annual report.
Past performance rules (Art 159(3)c) 2010 Law and Commission Regulation (EU)...
What You Need To Do
- Review and amend master-feeder agreements (per Art 79(1) 2010 Law) to require masters provide charge/fee data to feeders
- Ensure financial statements/annual reports disclose irregularities in specified sections and aggregate charges with audit report caveats if periods misalign
- Update KIIDs and marketing materials for past performance compliance, disclosing conversions/material changes per Regulation 583/2010 Articles 17, 19, 35
- Implement processes for ad hoc financial statements when accounting years differ, allocating audit/preparation fees appropriately
- Monitor CSSF website regularly for FAQ updates
Compliance Impact
Urgency: low—This 2013 guidance (Version 2) is outdated relative to 2026, with no new enforcement actions noted, but remains relevant for legacy UCITS master-feeder structures under the 2010 Law. It matters for audit/financial close processes and investor disclosures to avoid CSSF scrutiny, particularly in cross-border setups where ESMA UCITS rules apply; non-compliance risks reporting errors or investor complaints.
Asset Manager
Situation as at 31 January 2026
BankAsset ManagerBroker Dealer
Situation from January 2025 to January 2026
BankAsset ManagerBroker Dealer
Situation from January 2025 to January 2026
BankAsset ManagerBroker Dealer
Situation from January 2025 to January 2026
Asset ManagerBankBroker Dealer
Situation as at 31 December 2025
BankWealth ManagerAsset Manager
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
No description available.
BankWealth ManagerFintech
Administrative sanction imposed on Corestate Capital Holding S.A.
The CSSF published an administrative sanction on 6 February 2026 against Corestate Capital Holding S.A., likely for breaches in regulatory compliance such as depositary duties, oversight, or governance under Luxembourg financial laws, marking a repeat enforcement action following a prior sanction in June 2025. This matters for compliance professionals as it underscores CSSF's aggressive enforcement on alternative investment fund managers (AIFMs) and depositaries, signaling heightened scrutiny on safekeeping, oversight, and internal controls to prevent systemic risks in Luxembourg's fund sector. It highlights the regulator's willingness to impose public nominative sanctions, amplifying reputational damage alongside fines.
What Changed
No new regulatory changes or requirements are introduced; this is an enforcement action enforcing existing obligations under laws like the AIFM Law of 12 July 2013 (e.g., Articles 19(8), 19(9), 19(11) on safekeeping and oversight duties), the Law of 5 April 1993 on the financial sector, and Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013, e.g., Articles 92, 94, 96 on risk assessment, valuation verification, and cash flow monitoring).
What You Need To Do
- Conduct immediate gap analysis
- Enhance oversight duties
- Strengthen governance
- Firm-wide audit
- Training and reporting
Key Dates
20 June 2025 - Prior administrative sanction imposed on Corestate Capital Holding S.A., indicating ongoing non-compliance issues. DEADLINE
6 February 2026 - Publication date of the current administrative sanction on Corestate Capital Holding S.A., effective immediately as a public enforcement notice.
February 2023 –January 2024 for similar cases).
Compliance Impact
Urgency: High – This represents CSSF's pattern of public nominative fines (e.g., EUR 102,000 on JTC for depositary breaches, EUR 10,000 on Capitalis for AML non-cooperation), with escalation risks for repeat violations like Corestate's back-to-back sanctions. It matters due to Luxembourg's dominance in European fund assets (over EUR 5 trillion), where governance lapses can trigger outflows, license revocation, or cross-border ESMA scrutiny; firms must act preemptively to mitigate fines (typically EUR 10,000–102,000) and reputational harm from nominative publication.
Asset ManagerAll Firms
Administrative sanction imposed on Corestate Capital Holding S.A.
The CSSF published an administrative sanction on 6 February 2026 against Corestate Capital Holding S.A., likely imposing a fine for regulatory breaches, marking a repeat enforcement action following a prior sanction on the same entity dated 20 June 2025. This matters as it underscores CSSF's intensified supervisory scrutiny on Luxembourg-based investment managers, particularly regarding governance, asset safekeeping, and oversight duties under AIFM Law, signaling heightened enforcement risks for similar firms. Compliance teams should review it for patterns in depositary and transparency violations evident in recent CSSF cases.
What Changed
No new regulatory changes or requirements are introduced; this is an enforcement action highlighting non-compliance with existing obligations under Luxembourg's AIFM Law (notably Articles 19(8), 19(9), 19(11), and 51) and related delegated regulations like CDR 231/2013. Key breaches from analogous recent CSSF sanctions include inadequate safekeeping of assets (e.g., missing ownership verification and records), failure to oversee AIFM valuation policies and cash remittance timelines, improper delegation to custodians without due diligence, and weak internal governance such as conflicts of...
What You Need To Do
- Enhance oversight processes
- Strengthen governance
- For issuers like Corestate
Key Dates
20 June 2025 - Prior administrative sanction imposed on Corestate Capital Holding S.A..
6 February 2026 - Publication date of the current administrative sanction on Corestate Capital Holding S.A..
Compliance Impact
Urgency: High – This represents repeat enforcement on Corestate (second sanction in under a year), aligning with CSSF's pattern of nominative publications for severe, ongoing breaches in depositary and governance areas, as seen in JTC (EUR 102,000 fine for similar safekeeping/oversight failures) and BigRep SE (EUR 10,000 for reporting lapses). It elevates risks of fines, reputational damage, and market jeopardy assessments under AIFM Law Article 51, urging preemptive remediation amid CSSF's active 2023-2026 inspection cycle.
Asset ManagerAll Firms
No description available.
Asset ManagerHedge Fund
No description available.
Asset ManagerWealth Manager
Version 2.1
Asset ManagerWealth Manager
Press release 26/03
BankWealth Manager
No description available.
The Commission de Surveillance du Secteur Financier (CSSF) has updated its FAQ on crypto-asset investments by undertakings for collective investment, effective February 4, 2026, to align with the EU's Markets in Crypto-Assets Regulation (MiCAR). This update establishes clear investment limits and licensing requirements for UCITS and AIFs investing in crypto-assets, fundamentally reshaping how Luxembourg-regulated funds can structure crypto exposure.
What Changed
The regulatory framework introduces several material modifications:
*Investment Exposure Limits
UCITS may invest indirectly in crypto-assets for a maximum of 10% of their net asset value (NAV)**. These indirect investments are restricted to transferable securities that do not embed derivatives. AIFs open to retail investors other than well-informed investors face the same 10% NAV ceiling.
*MiCAR Alignment**
The FAQ modifications directly reflect the entry into force of Regulation (EU) 2023/1114 on markets in crypto-assets.
What You Need To Do
- *For UCITS Managers
- by-case assessment of crypto-asset investment impact on fund risk profiles
- specific risks (volatility, liquidity, technological risk)
- asset investments
- *For AIFMs Managing AIFs with Crypto Exposure
Key Dates
4 February 2026 - FAQ Version 7 effective date; MiCAR compliance requirements become operative DEADLINE
1 July 2026 - Deadline for Virtual Asset Service Providers (VASPs) to transition from registration to authorization under MiCAR or cease operations DEADLINE
Compliance Impact
Urgency: HIGH
Asset ManagerHedge FundFintech
No description available.
Wealth Manager
Administrative sanction imposed on Genève Invest (Europe) S.A.
The CSSF imposed an administrative sanction on 23 July 2025 against Genève Invest (Europe) S.A., a Luxembourg-regulated entity, for breaches of professional obligations, as detailed in a publication released on 4 February 2026. This enforcement action underscores the CSSF's focus on robust internal controls and compliance with investment rules, serving as a warning to investment firms on the consequences of organizational and conduct failures. Compliance professionals should note it as evidence of heightened CSSF scrutiny on fund managers handling client assets and counterparties.
What Changed
This is not a regulatory change or new requirement but an enforcement action highlighting existing obligations under Luxembourg law. Key breaches likely mirror patterns in recent CSSF sanctions, such as non-compliance with UCI Law provisions on investment policies (e.g., Articles 41, 43), sound accounting procedures (Article 109), and rules of conduct (Articles 111, CSSF Regulation 10-04), including improper cash deposits with unauthorized brokers and inaccurate asset valuation.
What You Need To Do
- Immediate review of counterparty due diligence
- Enhance valuation and accounting controls
- Conduct internal audits
- Update governance and reporting
Key Dates
23 July 2025 - Date of administrative sanction imposition on Genève Invest (Europe) S.A.
4 February 2026 - Publication date of the sanction document by CSSF.
Compliance Impact
Urgency: High – This sanction, published today (4 February 2026), signals ongoing CSSF off-site and on-site probes into fund operations, similar to fines imposed in July 2025 on Zeus Asset Management (€18,136 for UCI breaches) and a bank (reprimand for AML gaps). It matters due to escalating enforcement—fines calibrated to turnover (e.g., 10% in Zeus case)—and risks of reputational damage, especially for wealth managers with broker exposures. Non-compliance could trigger investigations, as CSSF considers infringement duration, cooperation, and history.
Asset ManagerWealth ManagerAll Firms
Version 7 – 04/02/2026
The CSSF has released Version 7 of its FAQ on Crypto-Assets for Undertakings for Collective Investment, updated on February 4, 2026, to reflect the entry into force of the Markets in Crypto-Assets Regulation (MiCAR). This guidance establishes binding investment limits, authorization requirements, and risk management standards for UCITS and AIFs investing in crypto-assets, fundamentally reshaping how Luxembourg-regulated collective investment schemes can engage with digital assets.
What Changed
The most significant regulatory modifications in Version 7 include:
*Investment Limits for UCITS
UCITS may invest indirectly in crypto-assets for a maximum of 10% of their net asset value (NAV)**. These indirect investments are limited to transferable securities that do not embed derivatives in accordance with Article 10 of the Grand-ducal Regulation of 8.
*Investment Limits for AIFs**
AIFs open to retail investors other than well-informed investors may invest in crypto-assets for a maximum of 10% of their NAV.
What You Need To Do
- *Immediate Compliance Steps
- *Portfolio Audit
- *Investment Policy Updates
- *Risk Management Assessment
- *Investor Notification
Key Dates
February 4, 2026 - FAQ Version 7 effective date (entry into force of MiCAR alignment)
July 1, 2026 - Deadline for Virtual Asset Service Providers (VASPs) to transition to CASP authorization or cease operations DEADLINE
No specific implementation grace period - The FAQ does not specify a transition period for existing funds exceeding the 10% limit; firms should clarify this with the CSSF immediately
Compliance Impact
Urgency Rating: HIGH
Asset ManagerHedge FundFintech
on alternative investment fund managers
Asset ManagerWealth Manager
No description available.
Asset ManagerWealth Manager
Administrative sanction imposed on a registered alternative investment fund manager (“AIFM”)
The CSSF imposed an administrative fine of EUR 10,000 on registered alternative investment fund manager (AIFM) C5 S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties and serves as a warning to supervised entities on the consequences of non-compliance with supervisory requests. It matters because it demonstrates the CSSF's willingness to publish names and impose fines for procedural lapses, potentially signaling increased scrutiny on AIFMs' AML/CFT obligations amid broader regulatory focus on financial crime risks.
What Changed
This is not a regulatory change or new requirement but an enforcement precedent highlighting existing obligations under the AML/CFT Law:
Mandatory annual submission of the CSSF financial crime questionnaire by supervised entities, including registered AIFMs, as part of the cooperation duty in Article 5(1).
Fines determined per Article 8-4(1), (2)(f), and (3)(a), considering circumstances under Article 8-5(1), with publication assessed for proportionality under Article 8-6(1).
No new rules introduced; reinforces that failure to respond to reminders constitutes a breach.
What You Need To Do
- Immediate verification
- Procedural enhancements
- Training and testing
- Engagement protocol
- Policy updates
Key Dates
4 April 2025 - Deadline for submission of the annual financial crime questionnaire covering the year ending 31 December 2024. DEADLINE
11 September 2025 - Date CSSF imposed the EUR 10,000 administrative fine on the AIFM for non-submission.
9 January 2026 - Publication date of the sanction decision.
30 January 2026 - Publication of the queried sanction notice (noting minor title discrepancy possibly referencing a separate but analogous case).[user provided]
Compliance Impact
Urgency: High – This sanction, though modest at EUR 10,000, exemplifies CSSF's proactive use of fines and public naming for AML reporting failures, with potential for higher penalties up to EUR 500,000 or 0.5% of turnover. It heightens risks for registered AIFMs amid CSSF's 2025-2026 priorities on financial crime, sanctions, and expanded reporting (e.g., Circular 25/894), where procedural lapses can trigger investigations, reputational damage, and barriers to remediation. Firms must prioritize to avoid escalation, especially post-publication on 30 January 2026.
Asset ManagerHedge Fund
No description available.
Asset ManagerWealth Manager
No description available.
Asset ManagerWealth Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
Asset ManagerWealth Manager
No description available.
BankAsset ManagerWealth Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankBroker Dealer
No description available.
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerPayment Provider
No description available.
BankBroker DealerAsset Manager
2026 update
BankWealth ManagerFamily Office
Communiqué
The CSSF's January 2026 enforcement report documents the results of its 2025 examination campaign on 2024 financial and non-financial disclosures by issuers under Luxembourg's Transparency Law. This publication is critical for compliance professionals because it reveals systematic compliance gaps across financial reporting (IFRS), sustainability reporting (ESRS), and Alternative Performance Measures (APMs), with 27% of enforcement decisions resulting in injunctions for non-compliance.
What Changed
The regulatory landscape has evolved significantly with the introduction of new sustainability reporting requirements:
ESRS Implementation (First Year): 2024 marked the first full reporting year under the European Sustainability Reporting Standards (ESRS), with the CSSF conducting a fact-finding exercise to assess reporting quality.
What You Need To Do
- *Financial Information (IFRS)
- *Enhanced Note Disclosures
- *Cash Flow Statement Presentation
- *Segment Reporting Completeness
- *Going Concern Assessment
Key Dates
4 July 2025 - European Commission adopted Delegated Act amending Taxonomy Disclosures (Omnibus package)
18 August 2025 - CSSF published full results of fact-finding exercise on ESRS reporting
5 December 2024 - CSSF published enforcement priorities press release for FY2024 reporting
January 2026 - CSSF published enforcement results report (current publication)
Compliance Impact
Urgency: HIGH
All Firms
relating to the fees to be levied by the Commission de Surveillance du Secteur Financier
BankAsset ManagerWealth Manager
Electronic transmission of documents to the CSSF
Circular CSSF 19/708 mandates the electronic transmission of specified documents to the CSSF via secure platforms like e-file or SOFiE, effective from February 1, 2019, replacing prior paper or other methods. This updated annex (as amended by Circular CSSF 21/790 and further revisions up to April 1, 2025) standardizes submissions for investment funds and related entities, reducing administrative burdens while ensuring document integrity and CSSF accessibility. Compliance professionals must monitor the dynamic annex list on the CSSF website to avoid nullified submissions.
What Changed
Mandatory Electronic-Only Submission: Documents listed in Annex I must be transmitted exclusively via e-file (http://www.e-file.lu) or SOFiE (http://www.cetrel-securities.lu/wp_static/what-do-we-offer/secured-reporting-channel-sofie-sort/), in PDF format supporting read access, printing, copy/paste, and word search; other methods post-February 1, 2019, are null and void.
Dynamic Annex Updates: The annex, published on the CSSF website, is regularly updated (e.g., latest noted April 1, 2025) and includes prospectuses, management regulations, annual reports, risk management reports, compliance...
What You Need To Do
- Register/access e-file or SOFiE platforms if not already (test/production environments available since February 2019)
- Consult and adhere to the latest Annex I for document list, nomenclatures, and formats (PDF with full functionality)
- Ensure submissions are final/official versions matching hard copies; use specified identifiers for UCIs/SIFs/SICARs
- Implement processes for automatic/manual transmission (e
- Train staff on responsibilities and integrate into reporting workflows; reference CSSF FAQs for closing documents
Key Dates
1 February 2019 - Entry into force Mandatory electronic transmission for listed documents; non-electronic submissions null and void.
28 January 2019 - Publication date of original Circular CSSF 19/708.
22 December 2021 - Amendment by Circular CSSF 21/790.
1 April 2025 - Latest annex update noted.
Ongoing - Regular checks required Entities must monitor CSSF website for annex updates. DEADLINE
Compliance Impact
Urgency: Low (for new implementations post-2019; medium for ongoing monitoring). This matters for operational efficiency and CSSF relations, as non-compliance risks rejected filings, delays (e.g., approvals under SFDR processes), or supervisory scrutiny, but long-standing rule (since 2019) with established platforms reduces immediate pressure. Firms must prioritize annex vigilance to avoid disruptions in routine reporting like annual reports or prospectuses.
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No description available.
This CSSF publication, dated January 12, 2026, identifies the specific population (likely a firm or individual) subject to an enforcement action, such as an administrative sanction, as part of the CSSF's transparency in supervisory measures. It matters because it signals CSSF's active enforcement priorities, potentially in areas like AML or reporting failures, enabling firms to assess similar risks in their operations and strengthen compliance to avoid parallel actions. Published amid rising focus on financial crime typologies like sexual extortion, it underscores the regulator's commitment to public accountability.
What Changed
No new regulatory changes or requirements are introduced in this publication, as it is an enforcement notice rather than a circular or guideline. It serves as a disclosure of an ongoing or concluded enforcement case, aligning with CSSF's practice of publishing sanction details to deter non-compliance and inform the market, without altering existing rules.
What You Need To Do
- For the named population
- For all supervised firms
- Update internal policies, train staff on enforcement precedents, and ensure robust reporting under Circular CSSF 19/726 or Transparency Law obligations
Compliance Impact
Urgency: High – Immediate relevance for the named party facing direct consequences; medium-to-high for peers due to CSSF's pattern of public enforcements signaling heightened scrutiny on financial crime, especially amid rising OCSE/FSEC cases noted in recent CSSF guidance. It matters as it could preview broader supervisory sweeps, impacting reputation, operations, and costs if similar vulnerabilities exist.
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amending Delegated Regulation (EU) 2016/1675 to add Russia to the list of high-risk third countries with strategic deficiencies
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Administrative sanction imposed on the alternative investment fund manager Premium Capital Management (“AIFM”)
The CSSF imposed a €10,000 administrative fine on 11 September 2025 against alternative investment fund manager (AIFM) Premium Capital Management for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation amid ongoing AML risks in Luxembourg. Compliance teams should view this as a reminder of the low tolerance for even administrative lapses, with potential for escalated fines in repeat cases.
What Changed
This is not a regulatory change but an enforcement precedent under existing rules: non-compliance with Article 5(1) of the AML/CFT Law, which mandates annual submission of a financial crime questionnaire ("Questionnaire") to the CSSF. The fine was calculated per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), considering circumstances under Article 8-5(1). Publication followed Article 8-6(1) after a proportionality assessment, confirming no market stability risks.
What You Need To Do
- Immediately review internal processes for annual Questionnaire submission, ensuring calendar invites and automated reminders for the 4 April deadline (covering prior year-end data)
- Conduct a gap analysis on AML/CFT cooperation obligations under Article 5(1), including response protocols to CSSF reminders or queries
- Update compliance calendars and train staff on escalation procedures; document all submissions with proof (e
- If late, proactively submit overdue items and request meetings if needed, as non-response forfeits mitigation opportunities
Key Dates
31 December 2024 - Reference year-end for the financial crime Questionnaire.
4 April 2025 - Statutory deadline for Questionnaire submission to CSSF. DEADLINE
11 September 2025 - Date CSSF imposed the €10,000 administrative fine after non-submission despite reminders.
9 January 2026 - Publication date of the sanction decision.
Compliance Impact
Urgency: Medium – This €10,000 fine for a straightforward reporting failure demonstrates CSSF's willingness to penalize non-cooperation swiftly, even without aggravating factors, but the amount is modest and targeted at administrative breaches. It matters as a warning shot in Luxembourg's AML landscape, where repeated failures could trigger higher fines (up to proportionality limits under Article 8-5), reputational damage via public naming, or supervisory escalations; firms should audit 2025/2026 reporting now to preempt similar actions, especially post-NRA updates.
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager Sunbricks GP S.à r.l. (“AIFM”)
The CSSF imposed a **€10,000 administrative fine on Sunbricks GP S.à r.l.**, an alternative investment fund manager, for failing to submit a mandatory annual financial crime questionnaire by the April 4, 2025 deadline, despite two formal reminders. This enforcement action demonstrates the CSSF's strict approach to cooperation obligations under Luxembourg's anti-money laundering and counter-terrorist financing (AML/CFT) framework and signals that non-submission of required compliance documentation—even without evidence of underlying financial crime—triggers regulatory penalties.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All professionals supervised, authorized, or registered by the CSSF must submit an annual questionnaire on financial crime by April 4 each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, which includes timely submission of requested documentation.
Administrative Fine Framework: The CSSF applies Article 8-4...
What You Need To Do
- regulated entities must
- *Establish Calendar Controls
- *Designate Responsible Parties
- *Prepare Documentation
- *Monitor Communications
Key Dates
April 4, 2025 – Annual financial crime questionnaire submission deadline (for year ending December 31, 2024) DEADLINE
Before September 11, 2025 – Two reminder notices issued by CSSF to Sunbricks GP
September 11, 2025 – Administrative fine decision date; questionnaire still not submitted
January 9, 2026 – Publication date of enforcement decision
2026 (for the year ending December 31, 2025).
Compliance Impact
Urgency: HIGH
Asset ManagerAll Firms
Administrative sanction imposed on the alternative investment fund manager Capitalis Premiere Group (“AIFM”)
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Capitalis Premiere Group on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation for Luxembourg-regulated entities. Compliance teams should note this as a low-value but public reminder of potential fines for administrative lapses in AML processes.
What Changed
This is not a regulatory change or new requirement but an enforcement precedent under existing rules: non-compliance with the annual financial crime questionnaire submission, mandated by Article 5(1) of the AML/CFT Law, triggers fines per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a). The CSSF considered all relevant circumstances under Article 8-5(1) to set the €10,000 fine amount and published the sanction nominatively after proportionality assessment per Article 8-6(1), confirming no market stability risks.
What You Need To Do
- Ensure timely submission of annual financial crime questionnaires by 4 April each year (for prior calendar year data); implement calendar reminders and escalation processes for CSSF requests
- Respond promptly to CSSF reminders or queries on AML/CFT compliance to avoid escalation to fines; document any delays with justification evidence
- No retroactive actions needed for this case, but conduct gap analysis on reporting workflows to prevent similar breaches
Key Dates
4 April 2025 - Deadline for submitting the annual financial crime questionnaire covering the year ending 31 December 2024. DEADLINE
11 September 2025 - Date CSSF imposed the €10,000 administrative fine on Capitalis Premiere Group for non-submission.
9 January 2026 - Date of CSSF publication of the sanction decision.
Compliance Impact
Urgency: Medium - This €10,000 fine is modest but publicly names the firm, amplifying reputational risk in Luxembourg's competitive fund domicile; it matters as a clear CSSF signal of zero tolerance for basic cooperation failures in AML, potentially foreshadowing stricter enforcement amid EU AML harmonization pressures. AIFMs face ongoing annual risk, with non-response despite reminders treated as willful breach; firms with weak reporting controls should prioritize fixes to avoid cumulative fines or escalations.
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager Lion Management (“AIFM”)
The CSSF imposed a €10,000 administrative fine on Lion Management, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the 4 April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing framework, with direct implications for all AIFMs regarding timely compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations. However, it reinforces critical compliance requirements:
Mandatory Annual Questionnaire Submission: All CSSF-supervised professionals, including AIFMs, must submit an annual questionnaire on financial crime by the specified deadline (in this case, 4 April 2025 for the year ending 31 December 2024).
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing establishes a non-negotiable obligation to cooperate with the...
What You Need To Do
- *Establish Calendar Controls
- *Designate Responsible Parties
- *Monitor CSSF Communications
- *Document Submission
- *Escalate Non-Compliance Immediately
Key Dates
4 April 2025 - Deadline for submission of annual financial crime questionnaire for year ending 31 December 2024 DEADLINE
11 September 2025 - Date CSSF imposed administrative fine after two reminders went unheeded
9 January 2026 - Publication date of the administrative sanction decision
Compliance Impact
Urgency: HIGH
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)
The CSSF imposed a €10,000 administrative fine on Max Gain Capital S.à r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but continued non-compliance triggers administrative fines under Article 8-4 of the...
What You Need To Do
- regulated entities must
- *Identify Reporting Obligations
- *Calendar Management
- *Documentation
- *Escalation Protocol
Key Dates
4 April 2025 - Deadline for submission of financial crime questionnaire for the year ending 31 December 2024 DEADLINE
Before 11 September 2025 - CSSF issued two reminders to Max Gain Capital after the missed deadline DEADLINE
11 September 2025 - CSSF imposed the €10,000 administrative fine
9 January 2026 - CSSF published the administrative sanction decision
Compliance Impact
Urgency: HIGH
Asset ManagerAll Firms
Administrative sanction imposed on the alternative investment fund manager Agriland Management S.A. (“AIFM”)
The Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial regulator, imposed a **EUR 10,000 administrative fine on Agriland Management S.A.**, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing (AML/CFT) framework and signals heightened scrutiny of compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action that clarifies existing obligations:
Mandatory Annual Reporting: All CSSF-supervised professionals must submit an annual questionnaire on financial crime by 4 April each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, including timely submission of requested documentation.
Enforcement Escalation: The CSSF will issue reminders for non-compliance, but continued failure to respond...
What You Need To Do
- *Establish Reporting Calendars
- *Designate Responsible Personnel
- *Respond to Regulatory Requests
- *Document Justifications
- *Monitor Supervisory Communications
Key Dates
4 April 2025 – Deadline for submission of financial crime questionnaire for year ending 31 December 2024 DEADLINE
Before 11 September 2025 – Two reminder notices issued by CSSF to Agriland Management S.A.
11 September 2025 – Administrative fine imposed
9 January 2026 – Sanction published by CSSF
Compliance Impact
Urgency: HIGH
Asset Manager
Administrative sanction imposed on the alternative investment fund manager Bedrock I GP S.à r.l. (“AIFM”)
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Bedrock I GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on timely supervisory compliance. It matters because it demonstrates that even modest fines are pursued for basic reporting lapses, potentially signaling heightened scrutiny on AIFMs' AML processes amid ongoing regulatory focus on financial crime risks.
What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing (AML/CFT Law). Specifically, it reaffirms the mandatory annual submission of the CSSF's financial crime questionnaire ("Questionnaire") by supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, as part of the cooperation duty in Article 5(1).
What You Need To Do
- Immediately verify submission status of the 2024 Questionnaire (or any outstanding); if overdue, submit promptly with justification to mitigate further escalation
- Implement automated calendar alerts and internal workflows for all CSSF reporting deadlines, including annual AML/CFT Questionnaire
- Conduct a compliance gap analysis on cooperation obligations under Article 5(1) AML/CFT Law, documenting reminder responses and evidence retention
- Train senior managers and compliance teams on supervisory interactions, including rights to request in-person meetings before fines
- Review governance for timely escalation of CSSF reminders to decision-makers
Key Dates
31 December 2024 - Reference period end for the Questionnaire covering financial crime compliance. DEADLINE
4 April 2025 - Statutory deadline for Questionnaire submission to CSSF. DEADLINE
11 September 2025 - Date of administrative fine imposition (€10,000) after non-submission despite reminders.
9 January 2026 - Publication date of the sanction decision by CSSF.
Compliance Impact
Urgency: Medium - This is a post-facto enforcement on a past breach (2024 reporting cycle), with the €10,000 fine relatively low, indicating proportionality for a first-time or isolated lapse. It matters as a leading indicator of CSSF's 2025-2026 focus on AML cooperation, with multiple similar AIFM sanctions published simultaneously, risking escalated fines or reputational harm for repeat offenders; firms should prioritize reporting hygiene to avoid public naming, which CSSF deems non-disruptive to markets here.
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Administrative sanction imposed on JTC (Luxembourg) S.A.
The CSSF imposed a €102,000 administrative fine on JTC (Luxembourg) S.A. on 23 July 2025 for breaches in its professional obligations as a depositary of non-financial assets under the AIFM Law, identified during an on-site inspection from February 2023 to January 2024 covering activities up to December 2022. This enforcement action highlights CSSF's scrutiny of depositary functions, particularly risk assessment and oversight controls, serving as a warning for similar entities to strengthen compliance amid rising supervisory focus on AIFM depositaries.
What Changed
This is an enforcement action, not a regulatory change; it enforces existing requirements under Article 51(1) (1st and 7th indents) and Article 51(2) (1st sub-paragraph, 3rd indent) of the amended Law of 12 July 2013 on AIFMs (AIFM Law), and related provisions like Article 92(1) of Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013).
What You Need To Do
- related entities) must
- Conduct immediate gap analyses on risk assessment processes for AIF strategies and AIFM organization per Article 92(1) CDR 231/2013
- Implement robust verification processes for AIFM compliance with asset delegation rules
- Ensure availability of key documentation and evidence of controls for the depositary function, addressing pre-2022 gaps if applicable
- Develop and test oversight processes, leveraging self-identified improvements and action plans as mitigating factors, as JTC did prior to inspection
Key Dates
February 2023 - January 2024 Period of CSSF on-site inspection on depositary obligations, covering activities up to December 2022.
23 July 2025 Date CSSF imposed the €102,000 administrative fine on JTC (Luxembourg) S.A.
9 January 2026 Date of official CSSF publication announcing the sanction.
Compliance Impact
Urgency: High – This matters due to the fine's size (€102,000), reflecting breach accumulation, severity, and duration, despite JTC's partial remediation; it signals intensified CSSF on-site scrutiny of depositary functions post-2023 inspections, with potential for higher penalties absent proactive controls. Depositaries face elevated enforcement risk, especially with unavailability of evidence pre-2022, urging swift remediation to avoid similar outcomes under Article 51 AIFM Law.
Asset Manager
Extract from the CSSF Newsletter No 300 – January 2026
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Press release 25/21(published on 22 December 2025, updated on 31 December 2025)
Asset ManagerWealth Manager
relating to specialised investment funds, investment companies in risk capital and undertakings for collective investment subject to Part II of the Law of 17 December 2010
Circular CSSF 25/901 consolidates and modernizes the supervisory framework for Luxembourg specialised investment funds (SIFs), investment companies in risk capital (SICARs), and undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs), including their sub-funds. It streamlines investment rules, diversification limits, borrowing, disclosures, and risk management while enhancing flexibility for sophisticated investors and formalizing prior informal guidance, reducing regulatory complexity without compromising investor protection.
What Changed
Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to 50% per issuer/UCI/asset or 70% per infrastructure investment for well-informed/professional investor funds, with CSSF derogations possible on justification.
What You Need To Do
- Review and update fund documents (e
- Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified
- Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries
- For retail-marketed funds
- Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts
Key Dates
late 2025 /early 2026 publications, but no explicit dates are provided.
Compliance Impact
Urgency: High – Formalizes prior informal guidance into binding rules with enhanced flexibility but stricter retail protections and disclosure mandates, requiring immediate document reviews/updates for non-compliant SIFs/SICARs/Part II UCIs to avoid supervisory scrutiny or authorization issues; critical for funds targeting private markets or retail.
Asset ManagerHedge Fund
Revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment (“UCI”) are subject
Circular IML 91/75, as amended up to CSSF Circular 25/901, consolidates and modernizes the supervisory framework for Luxembourg Part II UCIs, SIFs, and SICARs, refining rules on diversification, borrowing, risk-spreading, and disclosures while tailoring requirements to investor profiles. It matters because it streamlines fragmented regulations, enhances fund competitiveness, and formalizes CSSF expectations without mandating immediate changes for pre-existing funds, reducing compliance burdens while promoting transparency and flexibility. This update aligns administrative practices with market realities, repealing outdated circulars to eliminate ambiguity.
What Changed
Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs.
Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with justification; applies look-through for intermediary vehicles; harmonizes ramp-up (up to 12 months for liquid strategies, 4 years for private equity) and wind-down periods.
Borrowing Limits: New limits for SIFs/Part II...
What You Need To Do
- Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e
- Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications
- Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified
- Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance
- No immediate changes required for pre-19 Dec 2025 funds, but proactive alignment recommended to avoid future issues
Compliance Impact
Urgency: Medium – Not critical as existing funds are grandfathered with no retroactive changes required, but high relevance for new launches or material updates post-19 Dec 2025. It matters for operational efficiency (streamlined rules reduce fragmentation) and investor protection (tailored risks/disclosures), potentially lowering long-term costs while mitigating supervisory scrutiny; failure to update docs could delay approvals or trigger CSSF queries.
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amending Circular CSSF 22/811.Authorisation and organisation of entities acting as UCI administrators.
Circular CSSF 25/900, issued on 16 December 2025, amends Circular CSSF 22/811 to clarify governance principles, authorisation requirements, and operational standards for UCI (Undertakings for Collective Investment) administrators in Luxembourg, while reforming annual reporting obligations. It matters because it strengthens supervisory oversight, aligns with DORA for ICT outsourcing, and simplifies reporting to enhance efficiency and compliance in the fund administration sector.
What Changed
Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses governance, internal controls, operational organization, and risk management; detailed instructions are now on the CSSF website.
Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authorisation remains valid unless substantial changes occur, requiring re-application or prior...
What You Need To Do
- Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations
- Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025
- Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750)
- For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882
Key Dates
16 December 2025 - Issuance date; repeal of Annex B of Circular CSSF 22/811 effective immediately.
January 2025 - DORA entry into force, applying to ICT outsourcing for in-scope UCIAs.
31 December 2025 - New reporting framework (SAQ and updated modalities) applies to all financial years ending on or after this date.
Compliance Impact
Urgency: High - Immediate repeal of prior reporting Annex requires prompt process updates; new framework applies to FY 2025 year-ends (just past as of Jan 2026), risking supervisory scrutiny or penalties for non-compliance; DORA alignment adds operational resilience pressure amid ongoing CSSF focus on fund admin governance.
Asset ManagerWealth ManagerBank
Authorisation and organisation of entities acting as UCI administrators
Circular CSSF 22/811, as amended by Circular CSSF 25/900, establishes CSSF requirements for the authorisation, governance, internal organisation, and oversight of entities acting as UCI (Undertakings for Collective Investment) administrators in Luxembourg. It matters because it standardises practices amid regulatory, technological, and market evolutions, ensuring robust controls, risk management, and supervision for fund administration activities critical to Luxembourg's fund industry.
What Changed
Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure; application must include details per Annex A, with ongoing updates for substantial changes.
Scope of UCI Administration: Defines three core functions—registrar, NAV calculation/accounting, and client communication—requiring only one designated service provider per function per UCI (or compartment); UCI/IFM may perform functions internally or delegate with oversight.
Governance and Controls: Mandates sound...
What You Need To Do
- Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated
- Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function
- For delegations
- Conclude written contracts with UCI/IFM; submit annual UCIA activity reports
Compliance Impact
Urgency: High – Non-compliance risks CSSF sanctions, as authorisation is prior and ongoing; critical for Luxembourg fund ecosystem given evolutions in tech/markets/DORA. Firms must act promptly if unauthorised or misaligned, especially with annual reporting since 2023 and DORA integration; impacts operational models, delegations, and reporting immediately for active administrators.
Asset ManagerBankAll Firms
Press release 25/19
Asset ManagerWealth Manager
Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services
Circular CSSF 07/325, as amended by Circulars CSSF 21/765, CSSF 22/827, and most recently CSSF 25/898, establishes supervisory requirements for EU credit institutions and investment firms operating in Luxembourg via branches or free provision of services (FOPS). It matters for compliance professionals as it defines CSSF's host authority role, notification obligations, reporting, and enforcement powers, ensuring alignment with CRD and MiFID II while adapting to evolving EU rules.
What Changed
CSSF 21/765: Updated provisions following amendments to CSSF Regulation No 12-02, refining notification and operational requirements for branches and FOPS.
CSSF 22/827: Further amendments to align with CRD and MiFID II changes, including enhanced notifications for programme alterations (e.g., one-month prior written notice for changes in operations, services, or activities).
CSSF 25/898: Latest update (noted in CSSF Newsletter No 298, November 2025), incorporating recent legal/regulatory developments, such as refined reporting via eDesk portal, AML/CFT compliance assessments, and supervision...
What You Need To Do
- Notifications
- Supervision cooperation
Key Dates
One month before change effective date - Notify CSSF and home authority in writing of programme changes (e.g., operations, services, additional places of business) per CRD Article 36(3) and MiFID II Article 35(10).
Within 3 months of receipt - Home state authority communicates notification file to CSSF for branch/FOPS establishment.
Six months after financial year-end - Submit electronically signed SAQ (via eDesk), annual AML/CFT and conduct of business report (per Circular CSSF 19/731, to be repealed by CSSF 25/902), reviewed by REA.
Compliance Impact
Urgency: Medium - Matters due to recurring annual reporting (e.g., SAQ, AML/CFT within six months post-year-end) and prior notifications for changes, with CSSF enforcement powers (e.g., measures under LFS Article 46(2)) for non-compliance. Recent CSSF 25/898 update (Nov 2025) requires immediate review of processes for digital submissions, but no retroactive changes or hard deadlines post-2025; grandfathering for pre-existing setups reduces immediate pressure.
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Update of Circular CSSF 07/325 on Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services, as amended by Circulars CSSF 21/765 and CSSF 22/827
Circular CSSF 25/898 updates Luxembourg's supervisory framework for EU-origin credit institutions and investment firms operating in Luxembourg through branches or free provision of services. This amendment enhances the self-assessment questionnaire (SAQ) used by the CSSF to align supervisory oversight with current regulatory priorities, particularly adding UCI administration as a new thematic module. The update reflects the CSSF's evolving supervisory focus and requires affected institutions to demonstrate compliance with expanded assessment criteria.
What Changed
The circular introduces the following material modifications to Circular CSSF 07/325:
*New Supervisory Module
UCI administration** has been added as a thematic module to the self-assessment questionnaire, reflecting increased regulatory attention to fund administration practices.
*Enhanced Self-Assessment Framework**
Existing modules have been updated to better align with supervisory objectives and current regulatory priorities.
The revised SAQ now captures a broader range of supervisory points of focus relevant to branch operations and cross-border service provision.
*Scope...
What You Need To Do
- *Update Self-Assessment Processes
- Revise internal SAQ completion procedures to address the new UCI administration module
- Ensure all thematic modules reflect current supervisory expectations
- *Assess UCI Administration Compliance
- If the institution provides or is involved in UCI administration services, conduct a detailed assessment of compliance with CSSF expectations
Key Dates
31 October 2025 - Circular CSSF 25/898 published by the CSSF
19 December 2025 - Related modernization framework (Circular CSSF 25/901) entered into force for Part II UCIs, SIFs, and SICARs
No specific implementation deadline stated - Institutions should align their SAQ responses and compliance documentation with the updated framework immediately upon publication DEADLINE
Compliance Impact
Urgency: HIGH
BankBroker DealerAsset Manager
Press release 25/16
Asset ManagerWealth Manager
Press release 25/14
Asset ManagerWealth Manager
Press release 25/13
Bank
Press release 25/12
Asset ManagerWealth Manager
Press release 25/11
Asset ManagerWealth Manager
Press release 25/09
Asset ManagerWealth Manager
Press release 25/08
BankAsset ManagerWealth Manager Press release 25/06
Asset ManagerWealth Manager
Press release 25/05
BankAsset ManagerWealth Manager
Press release 25/03
BankWealth Manager
No description available.
BankWealth Manager