No description available.
Asset ManagerHedge Fund
No description available.
Asset ManagerHedge Fund
Version 3.1
Asset ManagerHedge Fund
Version 4.1
Asset Manager
Situation as at 30 June 2026
Asset Manager
No description available.
Asset ManagerHedge Fund
No description available.
Crypto ExchangeFintech
No description available.
All Firms
amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
All Firms
No description available.
All Firms
No description available.
ESMA has withdrawn its MiFID II/MiFIR market data Guidelines because their subject matter has been transposed into Commission Delegated Regulation (EU) 2025/1156 on the obligation to make market data available on a reasonable commercial basis. As a result, CSSF Circular 21/783, which implemented those ESMA Guidelines in Luxembourg supervisory practice, will become formally outdated from 23 August 2026, requiring MiFID firms and trading venues to ensure their policies and commercial terms now fully align with the directly applicable RTS in the Delegated Regulation.
What Changed
- - CSSF Circular 21/783, which applied ESMA’s Guidelines on MiFID II/MiFIR obligations on market data in Luxembourg, will cease to be applicable as of 23 August 2026 and is formally classified as...
- The supervisory reference framework for market data obligations in Luxembourg shifts from ESMA soft-law Guidelines to binding regulatory technical standards contained in Commission Delegated...
- Requirements on making market data available to the public on a “reasonable commercial basis” are now set out in directly applicable EU law, including detailed RTS criteria on cost-based pricing,...
- ESMA’s interpretative role via Guidelines is replaced by binding RTS, which reduces reliance on national circulars and increases harmonisation of market data rules across EU trading venues and data...
- Luxembourg firms can no longer rely on Circular 21/783 as the primary interpretative document for market data obligations; instead, their compliance frameworks must directly reference Delegated...
Suggested Considerations
- Identify and catalogue all internal policies, procedures, contractual templates, and pricing frameworks that reference CSSF Circular 21/783 or ESMA’s MiFID II/MiFIR market data Guidelines.
- Review Commission Delegated Regulation (EU) 2025/1156 in detail and map its RTS requirements (e.g. cost-based pricing, non-discriminatory access, data unbundling, publication formats) against current market data practices.
- Update market data pricing policies to ensure that fees are demonstrably based on reasonable commercial basis criteria defined in Delegated Regulation (EU) 2025/1156, including documentation of cost allocation and margin methodology.
- Revise market data access policies and client terms to ensure non‑discriminatory conditions and appropriate unbundling of pre‑trade and post‑trade data, in line with the RTS.
- Amend compliance manuals, MiFID/MiFIR control frameworks, and training materials to remove references to CSSF Circular 21/783 and ESMA Guidelines, replacing them with references to Delegated Regulation (EU) 2025/1156.
Key Dates
- Commission Delegated Regulation (EU) 2025/1156 is adopted, supplementing MiFIR with RTS on the obligation to make market data available to the public on a reasonable commercial basis
- ESMA Guidelines on MiFID II/MiFIR market data obligations are withdrawn; CSSF Circular 21/783, which incorporated these Guidelines into CSSF administrative practice, becomes outdated from this date
Compliance Impact
Non-compliance will now be assessed directly against binding RTS under Delegated Regulation (EU) 2025/1156, increasing enforcement risk if market data is priced or provided on terms that are not objectively “reasonable” or non‑discriminatory. Firms that fail to adapt their frameworks by 23 August 2026 risk supervisory findings, potential sanctions, and challenges to their market data commercial models.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Broker DealerBankAsset Manager
Administrative sanction imposed on Transnet Soc Ltd
The CSSF has published an administrative sanction dated 21 July 2026 in respect of Transnet Soc Ltd, a South African issuer with Luxembourg as home Member State under the Transparency regime. Although the notice itself is very brief, it clearly continues a pattern of enforcement against Transnet for breaches of the Luxembourg Law of 11 January 2008 on transparency requirements for issuers (Transparency Law), including a prior EUR 15,000 fine for late publication of its annual financial report. For compliance teams, this underscores the CSSF’s willingness to publicly sanction and name issuers that fail to meet periodic disclosure obligations, even for relatively modest monetary amounts.
What Changed
- As the 21 July 2026 CSSF notice is an enforcement publication (not a new rule), it does not introduce new regulatory requirements; it applies existing Transparency Law obligations.
- Issuers with Luxembourg as home Member State under the Transparency Law must publish annual financial reports within the statutory deadline, typically within four months of financial year-end, and...
- Failure to publish periodic financial information within the required time limits can result in administrative fines imposed by the CSSF under Article 25(2) of the Transparency Law.
- The CSSF will publicly disclose administrative fines imposed on issuers, including naming the issuer and the amount, in line with Article 26b of the Transparency Law.
- Issuers retain the right to challenge CSSF decisions before the Luxembourg Administrative Court within the period set by Article 27 of the Transparency Law (three months from notification), but...
Suggested Considerations
- Map all Transparency Law obligations applicable to your entity, including periodic (annual and half‑yearly) reporting and ongoing disclosure of regulated information, and document them in a compliance obligations register.
- Review and, where necessary, strengthen internal processes to ensure annual and half‑yearly financial reports are prepared, approved, and published within statutory deadlines for issuers with Luxembourg as home Member State.
- Implement a formal disclosure governance framework assigning clear responsibilities to senior management and the board for oversight of regulated information, including escalation procedures where delays or issues arise.
- Establish a calendar of regulatory reporting and publication deadlines, including internal cut‑off dates and contingency plans, and ensure it is monitored by compliance and finance functions.
- Conduct a gap analysis of prior disclosures (financial reports, major holdings notifications, inside information) to confirm that all items required under the Transparency Law have been published correctly and on time; remediate any deficiencies promptly.
Key Dates
– End of the financial year referenced in the prior CSSF sanction against Transnet Soc Ltd for failure to publish its annual financial report within the required time limit
– CSSF imposed an administrative fine of EUR 15,000 on Transnet Soc Ltd under Article 25(2) of the Transparency Law for late publication of the annual financial report as of 31 March 2021
– CSSF publishes the administrative sanction “Administrative sanction imposed on Transnet Soc Ltd”; this enforcement notice is made public in line with the Transparency Law’s publication requirements
– Statutory window during which Transnet Soc Ltd (or any sanctioned issuer) may lodge a court action against the CSSF decision with the Luxembourg Administrative Court under Article 27 of the Transparency Law
Compliance Impact
CSSF administrative fines under the Transparency Law may be modest in absolute value but carry material reputational and supervisory impact because the sanctions, the issuer’s name, and the failures are publicly disclosed. Persistent or repeated non‑compliance with transparency and disclosure obligations can trigger higher fines, closer supervisory scrutiny, and increased legal risk, including potential court actions and investor claims.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerBroker DealerBank No description available.
Broker DealerAsset Manager
amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
All Firms
Situation as at 30 June 2026
All Firms
Situation from June 2025 to June 2026
All Firms
Situation from June 2025 to June 2026
All Firms
No description available.
Asset ManagerHedge Fund
No description available.
Broker DealerAll Firms
No description available.
Broker DealerAll Firms
No description available.
All Firms
implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities
All Firms
implementing Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia
All Firms
Version of 13 July 2026
The CSSF has republished its MiFID II/MiFIR FAQ (Q&A) in a version dated 13 July 2026, consolidating guidance on investor protection, conduct of business, and reporting obligations applicable to Luxembourg MiFID firms. While the publication page itself is largely technical (cookies, website functioning), firms should treat the 13 July 2026 FAQ version as the current CSSF interpretative benchmark for MiFID II/MiFIR compliance, aligned with ESMA Q&As and recent EU‑level MiFID II/MiFIR review developments.
What Changed
- Because the visible page content provided is limited to technical and cookie‑related information, the key points below focus on the regulatory substance of the CSSF MiFID II/MiFIR FAQ (Q&A) as the...
- The CSSF confirms the application of MiFID II investor protection rules to Luxembourg investment service providers, including obligations on inducements, suitability, product governance, and best...
- The FAQ reiterates that investment services providers must inform clients clearly whether their investment advice or services are provided on an independent or non‑independent basis, and explains the...
- The FAQ clarifies that inducements are expressly prohibited when investment advice is provided on an independent basis and for portfolio management services, requiring firms to structure their...
- The CSSF guidance reflects product governance obligations: manufacturers must define a target market for each financial instrument based on clients’ knowledge and experience, financial situation,...
Suggested Considerations
- Review the latest CSSF MiFID II/MiFIR FAQ (13 July 2026 version) in full, comparing it against existing internal MiFID II/MiFIR policies, procedures, and controls to identify gaps or misalignments.
- Confirm and, where necessary, update client‑facing disclosures to clearly state whether investment services (especially advice and portfolio management) are provided on an independent or non‑independent basis, and ensure that inducement arrangements are consistent with this classification.
- Reassess inducement frameworks (commissions, fees, non‑monetary benefits) for investment advice and portfolio management to ensure that no prohibited inducements are received or retained where services are independent or involve portfolio management.
- Review and update product governance frameworks, including target market definition processes and product approval procedures, to ensure that each instrument’s intended target market is properly documented and consistently used by distributors.
- Examine best execution policies to confirm they are clear, detailed, and understandable to clients, and implement or enhance ongoing monitoring mechanisms (e.g. execution quality reports, periodic reviews) to evidence compliance with best execution obligations.
Key Dates
- Most revised MiFIR transparency requirements under the MiFID II/MiFIR review (amending Delegated Regulation) apply at EU level, influencing the content and focus of national FAQs and supervisory guidance, including CSSF’s
- CSSF publishes/updates the MiFID II/MiFIR FAQ version dated 13 July 2026, which becomes the current reference point for CSSF supervisory expectations on MiFID II/MiFIR compliance
Compliance Impact
Non‑compliance with CSSF’s MiFID II/MiFIR expectations can lead to supervisory findings, remediation orders, administrative sanctions, and potential reputational damage, particularly where investor protection (suitability, inducements, best execution) is compromised. Given the 2026 EU‑level MiFID II/MiFIR review changes and the updated FAQ, firms that fail to update frameworks risk being assessed against a higher and more current supervisory benchmark.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerBroker DealerBank No description available.
Broker DealerAll Firms
No description available.
All Firms
No description available.
FintechAll Firms
No description available.
All Firms
No description available.
All Firms
Press release 26/14
Asset ManagerHedge Fund
No description available.
Asset ManagerBroker DealerWealth Manager
Situation as at 31 May 2026
Asset Manager
Press release 26/13
All Firms
No description available.
What Changed
- - CSSF has published its 2025 supervisory disclosure covering supervisory measures and administrative penalties taken during the year.
- The publication serves as a public register-style disclosure of enforcement outcomes, increasing transparency around CSSF supervision and sanctioning activity.
- A related 2025 CSSF administrative sanction shows that AML/CFT non-compliance can result in a reprimand under the amended Luxembourg AML/CFT Law.
- The 28 July 2025 sanction confirms that CSSF can act where firms fail to maintain adequate professional AML/CFT obligations and related internal controls.
Suggested Considerations
- Review the firm’s AML/CFT control framework against the Luxembourg AML/CFT Law provisions that can trigger CSSF reprimands or sanctions, including governance, monitoring, and escalation controls.
- Verify that suspicious activity detection, investigation, and escalation procedures are documented, implemented, and tested for effectiveness.
- Reassess whether internal controls are sufficient to demonstrate timely compliance with professional AML/CFT obligations under CSSF supervision.
- Update remediation tracking to ensure supervisory findings are closed out promptly and supported by evidence of corrective action.
- Brief senior management on the reputational impact of public supervisory disclosures and ensure that recurring weaknesses are escalated to the board.
Key Dates
- CSSF’s supervisory disclosure covers **measures and administrative penalties for the year 2025**
- CSSF published the prior year’s supervisory disclosure page referencing the **2024** measures and penalties, showing the annual disclosure cycle
- CSSF issued an **administrative sanction** in an AML/CFT case, imposing a reprimand for non-compliance with the AML/CFT Law
Compliance Impact
The compliance impact is material because CSSF enforcement disclosures can expose weaknesses to the market, counterparties, auditors, and other regulators, creating reputational and supervisory pressure. Non-compliance with AML/CFT obligations can lead to public reprimands and potentially more severe measures if deficiencies persist or are systemic.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
BankAsset ManagerBroker Dealer No description available.
All Firms
No description available.
BankAsset ManagerBroker Dealer
No description available.
Broker DealerAsset Manager
No description available.
All Firms
No description available.
Broker DealerAsset Manager
No description available.
All Firms
No description available.
All Firms
No description available.
Asset Manager
This MMF Reporting Dashboard encompasses a set of indicators based on the data reported under Article 37 of the MMF Regulation, with data as from Q1/2020 onwards.
Asset Manager
under Article 5(4)(b)(iv) of the Law of 2013 and/or Article 101(3)(b), fourth indent of the Law of 2010 as introduced by the Law of 3 March 2026, transposing Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024
Asset Manager
No description available.
Bank
No description available.
Asset ManagerBroker DealerBank
No description available.
Crypto Exchange
implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities
All Firms
Situation as at 31 May 2026
All Firms
Situation from May 2025 to May 2026
All Firms
Situation as at 31 March 2026
Asset Manager
Situation from May 2025 to May 2026
All Firms
Situation from May 2025 to May 2026
All Firms
amending Delegated Regulation (EU) 2019/980 as regards the reduced content and the standardised format and sequence of the EU Follow-on prospectus and the EU Growth issuance prospectus
Asset ManagerBroker DealerAll Firms
Q&A CNC 26/037 titled “A reminder of the differences between annual accounts prepared for statutory purposes and annual accounts prepared for contractual purposes or on a voluntary basis” and interview with the chairman of the CNC (Mr. Yvan Thommes)
The CSSF is formally directing market participants’ attention to new guidance from the Luxembourg Commission des normes comptables (CNC) clarifying the distinction between **statutory annual accounts** and **contractual/voluntary annual accounts**, and to an interview announcing a forthcoming overhaul of Luxembourg accounting law. This matters for compliance and finance functions because it affects how firms label, prepare, approve, file and use financial statements in regulatory, contractual and investor contexts, and foreshadows medium‑term changes to the Luxembourg accounting framework.
What Changed
- - The CSSF endorses and promotes CNC Q&A 26/037 as the reference clarification on the concept of “comptes annuels établis à fins légales” (statutory annual accounts) versus annual accounts prepared...
- The Q&A provides clear criteria to distinguish statutory accounts from non‑statutory accounts, including their legal basis, approval process, filing and publication obligations, and permissible use...
- The CNC guidance clarifies that statutory annual accounts must fully comply with Luxembourg accounting law (including mandatory layouts, valuation rules and disclosures), whereas...
- The CNC addresses frequent practical questions from preparers, including whether financial statements prepared for banks, covenants, shareholders’ agreements, management incentive plans or...
- The CSSF communicates that misunderstandings between statutory and contractual accounts remain common, implicitly warning against the risk of using non‑statutory statements in contexts where...
Suggested Considerations
- Identify all sets of financial statements prepared by the firm or its Luxembourg entities (statutory, covenant/banking, shareholder/management, group‑reporting, voluntary) and map which are statutory annual accounts under Luxembourg law and which are contractual or voluntary.
- Review the CNC Q&A 26/037 in detail and update internal accounting manuals and group reporting policies to embed the CNC’s definitions, terminology and criteria for statutory versus non‑statutory annual accounts.
- Implement a clear labelling and disclosure convention so that all non‑statutory financial statements explicitly state their nature (contractual or voluntary) and are not presented or communicated as statutory annual accounts.
- Update templates for board and shareholder approvals, minutes and resolutions to ensure that the correct set of statutory annual accounts is approved for legal purposes such as profit appropriation, dividend distribution, capital reduction and regulatory filings.
- Review all contractual arrangements (loan agreements, bond indentures, shareholder agreements, management incentive plans and service contracts) to determine whether they require statutory annual accounts or allow contractual/adjusted accounts, and align documentation and practice accordingly.
Key Dates
– Publication of the interview with the CNC chairman in Paperjam announcing that Luxembourg accounting legislation will be subject to a comprehensive overhaul
– CSSF communiqué published, formally drawing attention to CNC Q&A 26/037 and the CNC chairman’s interview, and thereby activating supervisory expectations that firms take these clarifications into account
– Effective dates for the planned overhaul of Luxembourg accounting legislation remain to be defined; firms should anticipate consultation and transition periods once draft law is published
Compliance Impact
Misclassification or misuse of contractual/voluntary accounts where statutory annual accounts are legally required can lead to breaches of Luxembourg company law, invalid shareholder resolutions, misstatements in regulatory or investor reporting, and potential CSSF supervisory findings. Consistent application of the CNC guidance will be expected in future inspections and could influence audit opinions and governance assessments.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
BankAsset ManagerBroker Dealer No description available.
Asset ManagerWealth ManagerAll Firms
Version 1.4
Asset ManagerHedge Fund
No description available.
Broker DealerAll Firms
Version 3.1
Asset ManagerHedge Fund
Version 3.1
Asset ManagerHedge Fund
Further details concerning the AMLA webinar of 10 June 2026 from 10 am to 12 pm CEST
All Firms
No description available.
The CSSF has launched a consultation on national **Guidance on Money Market Fund Weekly Liquid Asset (WLA) Levels**, aligned with the European Commission’s 2026 MMF report, which defines “market resilience” WLA benchmarks above the MMFR regulatory minimums. This signals a move toward **enhanced liquidity risk management and intensified supervisory scrutiny** for Luxembourg‑authorised MMFs whose WLA levels fall below these resilience benchmarks, even if they remain above the legal minimum.
What Changed
- - The CSSF, in coordination with the European Commission, AMF (France) and Central Bank of Ireland, is consulting on national guidance that operationalises the Commission’s “market resilience” levels...
- The guidance will introduce non-binding but supervisory‑relevant WLA benchmarks designed to indicate when an MMF’s liquidity profile may warrant closer scrutiny and additional supervisory engagement.
- The consultation builds on the European Commission’s 11 May 2026 report, which identifies WLA benchmarks of 20% for VNAV MMFs and 40% for LVNAV and CNAV MMFs, compared with the MMFR regulatory minima...
- The guidance is intended to support more consistent and well‑calibrated supervision of MMFs across the EU, specifically on liquidity resilience under stress.
- MMFs that fall below the identified “market resilience” WLA levels, even while remaining compliant with the MMFR minimum percentages, can expect increased supervisory scrutiny, closer monitoring and...
Suggested Considerations
- Review the CSSF consultation paper “Guidance on Money Market Fund Weekly Liquid Asset Levels” in detail and map the proposed WLA resilience benchmarks against existing MMF liquidity policies, procedures and internal limits.
- Perform a quantitative impact analysis comparing each MMF’s historical and current WLA levels against both MMFR minimum requirements and the Commission’s market resilience benchmarks (20% for VNAV; 40% for LVNAV and CNAV) to identify potential shortfalls or pressure points.
- Assess and, where necessary, update MMF liquidity risk management frameworks to incorporate explicit internal WLA targets, triggers and escalation procedures linked to the new resilience benchmarks, including governance oversight and board reporting.
- Integrate the proposed WLA resilience levels into stress testing programmes under Article 28 MMFR, ensuring scenarios reflect the ability of funds to maintain or restore WLA around the benchmark levels under severe but plausible market stress.
- Revisit know‑your‑investor / liability profile analysis under Article 27 MMFR to ensure that internal WLA targets adequately reflect investor concentration, redemption behaviour, dealing frequency and distribution channels.
Key Dates
– European Commission publishes its report on the adequacy of the MMFR and FAQs, identifying market resilience WLA levels for VNAV and CNAV/LVNAV MMFs
– CSSF informs the market of the Commission’s MMF report and FAQs and flags the identified WLA “market resilience” benchmarks
– CSSF publishes the communiqué launching the consultation on “Guidance on Money Market Fund Weekly Liquid Asset Levels.”
– Deadline for stakeholders to submit electronic responses on the consultation to the CSSF at opc_prud_risk@cssf.lu
Compliance Impact
The immediate legal impact is limited because the text is a consultation on guidance, not a binding rule change, but the direction of travel is towards higher de‑facto liquidity expectations and more intrusive supervision where WLA levels fall below resilience benchmarks. Non‑alignment with the eventual guidance is likely to result in increased supervisory challenge, potential remediation demands and heightened risk that liquidity weaknesses are escalated within the CSSF’s prudential risk framework.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundBank
Consultation Paper
The CSSF has launched a consultation on new **Guidance on Money Market Fund (MMF) Weekly Liquid Asset Levels**, signalling its intention to clarify supervisory expectations on the calibration and use of weekly liquid asset (WLA) buffers under the EU Money Market Funds Regulation (MMFR). This matters for compliance teams because it will likely drive changes to MMF liquidity risk frameworks, escalation triggers, governance around liquidity thresholds, and potentially the design of internal stress tests and contingency plans.
---
What Changed
- Given the consultation nature and the absence of a published consultation text in the extract, the following points reflect what compliance teams should reasonably anticipate and prepare for, based...
- The CSSF is consulting on formal guidance that will specify how MMFs domiciled in Luxembourg should determine, monitor, and maintain weekly liquid asset levels under the EU Money Market Funds...
- The guidance is expected to operationalise the MMFR WLA requirements (for example, minimum weekly liquidity levels and interaction with redemption activity) by setting out supervisory expectations on...
- The consultation will likely address the interaction between WLA levels and the use of liquidity management tools (such as gates, fees, or suspensions), including expectations on when and how...
- The CSSF is expected to clarify how MMFs should incorporate WLA targets and thresholds into their internal risk management policies, including stress-testing assumptions, early warning indicators,...
Suggested Considerations
- Review the CSSF consultation paper in full as soon as it is available and identify all proposed expectations relating to weekly liquid asset levels, monitoring, and escalation.
- Map the proposed CSSF guidance against current MMF liquidity policies, prospectus disclosures, and internal procedures to identify gaps and potential areas needing enhancement.
- Assess whether existing MMF weekly liquidity monitoring tools, dashboards, and reporting are sufficient to meet anticipated CSSF expectations on frequency, granularity, and early warning indicators.
- Evaluate the current escalation framework for declining WLA levels, including board and senior management involvement, and update governance documentation to align with the likely CSSF approach to thresholds and decision‑making.
- Review MMF stress‑testing methodologies to ensure that scenarios adequately capture severe but plausible redemption and market stress in relation to WLA levels and that results are integrated into risk appetite and contingency planning.
Key Dates
– Expected date for CSSF to publish final guidance on MMF weekly liquid asset levels, following review of consultation feedback
– CSSF publishes consultation communiqué “Guidance on Money Market Fund Weekly Liquid Asset Levels” and opens consultation on its proposed guidance
– Expected closing date for industry comments on the consultation (to be confirmed once the full consultation paper and response deadline are made available by CSSF)
Compliance Impact
Non‑compliance with the forthcoming CSSF guidance, once finalised, could result in supervisory findings, remediation programmes, and potential restrictions on MMF activities, particularly in stressed markets where liquidity management failures are highly scrutinised. Given MMFs’ systemic importance, firms should treat this as a high‑impact development for liquidity risk management, board oversight, and investor protection.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundBank
Administrative sanction imposed on a registered alternative investment fund manager
The CSSF has published an administrative sanction dated 17 April 2026 imposed on a **registered alternative investment fund manager (registered AIFM)**, but the public notice contains no detail on the nature of the breach, legal basis, or penalty level, which are presumably only available in the linked PDFs. For compliance teams, this is another data point that the CSSF is actively enforcing the AIFMD and related Luxembourg implementing laws against even registered (sub‑threshold) AIFMs, not only fully authorised managers.
Because the body text and PDFs are not accessible from the prompt, the analysis below focuses on the **regulatory framework and typical CSSF enforcement themes** that are most likely relevant, and how compliance teams at AIFMs should respond.
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What Changed
- There are no formal rule changes announced in the short notice itself; however, the enforcement action reinforces several practical expectations that compliance teams should treat as de‑facto...
- CSSF confirms that registered alternative investment fund managers are fully subject to Luxembourg’s AIFM framework, including the Law of 12 July 2013 on alternative investment fund managers and the...
- CSSF reiterates, through enforcement practice, that registration status (sub‑threshold AIFM) does not shield managers from administrative sanctions where organisational, conduct, reporting, or...
- CSSF continues its policy of public naming and shaming through publication of administrative sanctions, signalling that reputational impact is a key component of its deterrence strategy.
- The sanction underscores the CSSF’s readiness to use its full sanctioning toolkit under the AIFM Law, which can include monetary fines, public statements, and prohibitions or restrictions on...
Suggested Considerations
- Obtain and review the full CSSF sanction decision PDFs published with the 17 April 2026 administrative sanction to identify the specific legal provisions, facts and control failures cited.
- Map the identified breaches (e.g. governance, risk management, reporting, valuation, delegation, marketing, or conduct of business) against your firm’s current policies and procedures under the Law of 12 July 2013 on AIFMs and the AIFMD framework.
- Perform a targeted gap analysis for registered AIFMs, focusing on whether “light” registration has led to under‑resourced compliance, risk, valuation, or reporting functions that could attract similar enforcement.
- Review and, where necessary, update internal governance arrangements, including board oversight, documented decision‑making, and escalation processes for regulatory issues, to align with CSSF expectations evidenced in recent sanctions against AIFMs and management companies.
- Test the effectiveness of regulatory reporting and disclosure processes (including Annex IV reporting, investor disclosures, periodic reporting, and prospectus/issuing document accuracy) to ensure they are complete, timely and consistent with CSSF rules.
Key Dates
- CSSF adopts an administrative sanction decision against a registered alternative investment fund manager
- CSSF publishes the administrative sanction notice on its website, including links to the detailed sanction decision in PDF form
Compliance Impact
The compliance impact is medium to high: while the publication does not create new rules, it underscores that the CSSF will actively sanction even registered AIFMs and publicly disclose those sanctions, increasing both regulatory and reputational risk for weakly controlled managers. Firms that treat registration as a “lighter” supervisory regime without proportionate controls are particularly exposed to similar action.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundWealth Manager
No description available.
All Firms
Press release 26/11
Asset ManagerWealth Manager
No description available.
The CSSF has published a Feedback Report following a thematic review of the **valuation framework for less liquid and illiquid assets**, focused primarily on Luxembourg AIFMs managing AIFs in asset classes such as private equity, real estate, infrastructure, private debt and fund of funds, and on UCITS “trash ratio” positions under Article 41(2) of the UCI Law. All Luxembourg IFMs are explicitly expected to benchmark their existing valuation frameworks against the CSSF’s observations and recommendations and to implement corrective measures, with valuation risk confirmed as a key supervisory priority for 2026.
What Changed
- - The CSSF publishes a dedicated Feedback Report on the thematic review of valuation frameworks for less liquid and illiquid assets and formally expects IFMs to use it as guidance for implementing...
- All Luxembourg IFMs are required to conduct a benchmarking exercise of their valuation frameworks against the CSSF’s observations and recommendations set out in the new Feedback Report.
- Where gaps or weaknesses are identified through this benchmarking, IFMs are expected to implement corrective measures to strengthen their valuation policies, procedures and lifecycle controls for...
- The thematic review scope formally covers AIFMs of AIFs investing in less liquid and illiquid assets (including private equity, real estate, infrastructure, private debt and fund of funds), and, on...
- The CSSF explicitly links this thematic work to previous supervisory exercises (ESMA CSA on valuation, CSSF self‑assessment questionnaires, and on‑site inspection feedback) and consolidates...
Suggested Considerations
- Perform a structured benchmarking of existing valuation policies, procedures, methodologies and controls against the detailed observations and recommendations in the CSSF Feedback Report on valuation frameworks for less liquid and illiquid assets.
- Document, at IFM and fund level, all identified gaps or weaknesses in the current valuation framework, including for AIFs in illiquid strategies and UCITS Article 41(2) trash ratio positions.
- Develop and approve a remediation plan with clear owners, milestones and target dates to address identified shortcomings in valuation governance, methodologies, model validation, data sources and control processes.
- Review and, where necessary, update valuation policies and procedures to ensure they explicitly cover less liquid and illiquid assets, stressed market conditions, use of external valuers, and documentation standards across the investment lifecycle.
- Enhance valuation governance by clearly defining roles and responsibilities (including segregation from portfolio management where applicable), escalation procedures, and oversight by the board/senior management.
Key Dates
– CSSF thematic review launched by dedicated questionnaire to IFMs, with work conducted through 2024 and 2025 (contextual start of the current thematic exercise)
– CSSF conducts off‑site and on‑site work as part of the dedicated thematic review on valuation frameworks for less liquid and illiquid assets
– Valuation risk for less liquid and illiquid assets is confirmed as a key supervisory priority, implying heightened supervisory focus and potential follow‑up actions during the year; no hard implementation deadline is set but prompt action is implicitly expected
– CSSF publishes the Communication and Feedback Report on the thematic review and formally expects IFMs to perform a benchmarking exercise and implement corrective measures as needed
Compliance Impact
Failure to benchmark and remediate valuation frameworks for less liquid and illiquid assets exposes IFMs to material supervisory risk, including targeted reviews, formal remedial orders or sanctions, particularly given the CSSF’s designation of valuation risk as a key supervisory priority in 2026. Deficient valuation practices also heighten the risk of NAV errors, investor detriment and potential civil liability or reputational damage.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundWealth Manager No description available.
Broker DealerAll Firms
No description available.
The CSSF has issued a feedback report on a thematic review of the **valuation framework for less liquid and illiquid assets**, signalling intensified supervisory focus on how Luxembourg investment fund managers value complex, hard‑to‑price positions. This matters because it will drive stricter expectations around valuation governance, model oversight, data validation, and the interaction between valuation, liquidity management, and investor protection for funds holding such assets.
Although the specific 2026 feedback report text is not yet available, it clearly follows and deepens the CSSF’s 2023 Feedback Report on ESMA’s CSA on Valuation and its 2026 supervisory priorities on valuation, with a narrower focus on less liquid and illiquid assets.
What Changed
- Based on the prior CSSF feedback on valuation and the indicated thematic focus, compliance teams should expect the following concrete expectations to apply specifically to less liquid and illiquid...
- Investment fund managers must maintain concise, centralised, and comprehensive valuation policies and procedures that explicitly cover all asset types, including less liquid and illiquid instruments,...
- Valuation policies must define and justify the valuation methodologies and models used for less liquid and illiquid assets, including the hierarchy of methods, model selection criteria, and...
- Firms must perform robust model governance for valuation models used on less liquid and illiquid assets, including independent model review (by staff not involved in model development), back‑testing,...
- Valuation frameworks must explicitly address stressed market conditions for illiquid and thinly traded assets, including triggers for stress conditions, alternative valuation methodologies under...
Suggested Considerations
- Conduct a comprehensive gap analysis of existing valuation policies and procedures against the CSSF’s feedback on valuation, with specific attention to less liquid and illiquid assets, and document all identified weaknesses and remediation actions.
- Update and formally approve valuation policies and procedures to clearly define methodologies, model hierarchies, and data source selection for less liquid and illiquid assets, including explicit provisions for stressed market conditions.
- Implement or enhance a formal valuation model governance framework for illiquid asset models, including independent model validation, periodic back‑testing, documentation of assumptions, and at least annual model reviews.
- Review and, where necessary, redesign organisational arrangements to ensure the operational and hierarchical independence of the valuation function from portfolio management, and adjust remuneration policies to avoid performance‑linked incentives for valuation staff.
- Strengthen controls over external pricing providers and external valuers by documenting selection criteria, performing initial and ongoing due diligence, challenging methodologies, and periodically back‑testing third‑party valuations of illiquid assets.
Key Dates
– CSSF publishes its Feedback Report on the ESMA Common Supervisory Action (CSA) on Valuation, setting out broad expectations for valuation frameworks, including for less liquid assets
– Deadline by which all IFMs managing UCITS and/or AIFs were required to complete a comprehensive assessment of their valuation frameworks and implement necessary corrective measures in line with the 2023 CSSF Feedback Report on valuation
– CSSF identifies valuation as an ongoing key supervisory priority for the investment fund sector in its 2026 priorities, with specific focus on IFM valuation organisation and processes
– CSSF publishes the new Feedback Report on the thematic review of valuation frameworks for less liquid and illiquid assets, signalling renewed and more granular supervisory scrutiny of this area
– CSSF is expected to conduct follow‑up supervisory work (off‑site reviews and on‑site inspections) to test implementation of its expectations on valuation of less liquid and illiquid assets; firms should plan remediation programmes within months rather than years
Compliance Impact
Non‑compliance exposes firms to heightened risk of CSSF supervisory measures, including remediation orders, restrictions on activities, and possible enforcement actions, especially where valuation weaknesses have led or could lead to investor detriment. Given the CSSF’s explicit supervisory priority on valuation, firms with significant illiquid exposures should treat this as a high‑impact issue requiring proactive remediation and robust documentation.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundBank amending the regulatory technical standards laid down in Delegated Regulation (EU) 2019/979 as regards updating the list of data necessary for the classification of prospectuses and the list of information that can be incorporated by reference into prospectuses
Commission Delegated Regulation (EU) 2026/395 of 23 February 2026 amends the Prospectus Regulation RTS in Delegated Regulation (EU) 2019/979 to update: (i) the **data set used for ESMA classification and filing of prospectuses** and (ii) the **categories of information that may be incorporated by reference** into a prospectus.
For compliance teams in Luxembourg and across the EU, this means prospectus production, filing templates, and reference documentation frameworks must be revised so that all new prospectuses and supplements meet the updated RTS data and incorporation-by-reference standards under Regulation (EU) 2017/1129.
What Changed
- - The amending Delegated Regulation updates the list of data fields required for the classification of prospectuses under Delegated Regulation (EU) 2019/979, impacting how issuers and their advisors...
- The RTS amendment revises the list of information that can be incorporated by reference into a prospectus, narrowing or clarifying which external documents (e.g.
- Prospectus classification data fields are expected to better align with current ESMA Prospectus Register needs (for example finer product type, offer type, and home/host state metadata), requiring...
- The updated incorporation-by-reference list seeks to ensure that only readily accessible and reliable information may be referenced, which will affect how issuers structure cross‑references to annual...
- National competent authorities, including the CSSF, will apply the revised RTS when reviewing and approving prospectuses and supplements, meaning filings that use outdated data sets or ineligible...
Suggested Considerations
- Map all existing prospectus templates, checklists and workflows against the revised Delegated Regulation (EU) 2019/979 data fields and immediately identify gaps in prospectus classification data and reference documentation.
- Update internal prospectus data dictionaries and metadata schemas so that all new and updated prospectuses capture the full revised list of ESMA classification data required by the amended RTS.
- Review and revise the firm’s incorporation‑by‑reference policy, including standard clauses and cross‑reference tables, to ensure only information categories permitted under the updated RTS are incorporated by reference.
- Reconfigure electronic filing tools and interfaces used for submissions to the CSSF (and other NCAs) so that they generate and transmit the updated RTS data set required for classification and ESMA register purposes.
- Train legal, capital markets, and product teams involved in prospectus drafting on the new RTS requirements, including examples of acceptable and non‑acceptable incorporation‑by‑reference documents.
Key Dates
- Original Delegated Regulation (EU) 2019/979 is adopted, setting the RTS on key financial information, publication and classification of prospectuses, advertisements, supplements and incorporation by reference
- Commission Delegated Regulation (EU) 2026/395 is adopted, amending Delegated Regulation (EU) 2019/979 on the list of data necessary for prospectus classification and the list of information allowed to be incorporated by reference
- CSSF publishes notice of Delegated Regulation (EU) 2026/395, signalling its relevance for Luxembourg‑supervised entities and prospectus approval processes
- The Delegated Regulation will enter into force on the date specified in the Official Journal; in line with standard EU practice, firms should expect application from a specified date shortly after OJ publication and plan prospectus updates accordingly
Compliance Impact
Non‑compliance can lead to prospectus approval delays, rejection of filings, or required resubmissions, which may disrupt issuance timetables and investor communications. Persistent or material breaches may expose firms and issuers to supervisory measures, sanctions, and reputational risk for failing to meet Prospectus Regulation standards.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
BankBroker DealerAsset Manager
No description available.
Asset ManagerHedge Fund
No description available.
CSSF is pressing Luxembourg market participants to complete T+1 readiness surveys by **9 June 2026** and to engage with ESMA’s broader T+1 consultation work, because the EU settlement cycle moves to **T+1 on 11 October 2027** under CSDR. The publication matters because it signals that supervisors are already assessing industry preparedness and that firms must accelerate post-trade process changes, especially around allocations, confirmations, and electronic messaging.
What Changed
- - CSSF is requiring market participants to complete the national competent authorities’ T+1 readiness survey by 9 June 2026, with responses visible only to CSSF and ESMA.
- CSSF is strongly encouraging participation in the EU T+1 Industry Committee second readiness survey to support a Union-wide assessment of market preparedness.
- CSSF is flagging that the transition to T+1 settlement on 11 October 2027 under CSDR will require coordinated changes across the trading and post-trading chain.
- CSSF is warning that forthcoming amendments to the RTS on Settlement Discipline are expected to be endorsed by the European Commission and will further define operational requirements for the T+1...
- ESMA’s revised guidelines on standardised procedures and messaging protocols are intended to make post-trade communication faster, clearer, and more consistent across the EU.
Suggested Considerations
- Complete the CSSF T+1 readiness survey before 9 June 2026 and ensure the submission accurately reflects the firm’s current operational readiness.
- Participate in the EU T+1 Industry Committee second readiness survey to demonstrate engagement with the EU-wide readiness process.
- Review the firm’s allocation and confirmation workflows to ensure they can operate within T+1 timeframes.
- Replace any reliance on oral, manual, or non-machine-readable communications with electronic, standardised messaging channels unless a temporary technical disruption justifies an exception.
- Align internal messaging standards with international messaging protocols used for post-trade communication.
Key Dates
- CSSF publishes the reminder on T+1 readiness, survey participation, and ESMA’s consultation work
- Deadline to complete the CSSF national competent authorities’ T+1 readiness survey
- Expected application date of the revised ESMA guidelines on standardised procedures and messaging protocols
- T+1 settlement cycle becomes effective under CSDR
Compliance Impact
Non-participation in the surveys will not itself appear to be the substantive T+1 breach, but it will materially weaken supervisory visibility and may invite follow-up scrutiny from CSSF and ESMA. Firms that fail to adapt allocations, confirmations, and messaging processes risk being unprepared for the 7 December 2026 guidance phase-in and the 11 October 2027 settlement-cycle change, which could create settlement fails, operational disruption, and conduct/governance issues.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
All FirmsAsset ManagerBank No description available.
CSSF reminds Luxembourg market participants that the EU move to a **T+1 settlement cycle under CSDR on 11 October 2027** is now in execution phase and links this directly to concrete supervisory tools: mandatory-like readiness surveys, RTS on Settlement Discipline amendments, and new ESMA post‑trade communication guidelines. For compliance teams, this is a front‑to‑back operating model change: firms must demonstrate T+1 readiness to CSSF/ESMA, transition to fully electronic, standardised post‑trade communication, and align allocations/confirmations processes to tighter regulatory timelines.
What Changed
- - The EU settlement cycle for in‑scope financial instruments under CSDR will shorten from T+2 to T+1 with effect from 11 October 2027, materially reducing the time to complete front‑to‑back trade,...
- CSSF has launched a national competent authorities’ T+1 readiness survey and sets a firm completion deadline of 9 June 2026 for Luxembourg market participants, treating it as a critical supervisory...
- In parallel, CSSF strongly encourages Luxembourg firms to complete the EU T+1 Industry Committee (EUIC) second readiness survey to support an EU‑wide view of T+1 readiness and potential systemic...
- ESMA’s final draft amendments to the CSDR RTS on Settlement Discipline will introduce additional operational requirements specifically designed to support T+1 (e.g.
- ESMA has launched a consultation on updated guidelines on standardised procedures and messaging protocols for allocations, confirmations and affirmations, explicitly aimed at facilitating the T+1...
Suggested Considerations
- Identify all group entities and business lines in Luxembourg that are in scope of CSDR T+1 (trading, clearing, settlement, custody, collateral, fund dealing) and formally designate a T+1 programme owner at senior management level.
- Complete the CSSF T+1 national competent authorities’ survey in full and by 9 June 2026, ensuring that responses accurately reflect current readiness, key risks, dependencies on third parties, and planned remediation milestones.
- Arrange for appropriate internal review and sign‑off (e.g. by Compliance and relevant senior management) of the responses to both the CSSF survey and the EUIC second readiness survey before submission.
- Participate in the EU T+1 Industry Committee second readiness survey and ensure the firm’s answers are consistent with the information provided to CSSF and with internal T+1 project documentation.
- Perform a comprehensive T+1 impact assessment of front‑to‑back trade flows, covering trade execution, allocation, confirmation, affirmation, clearing, settlement, collateral movements, cash and liquidity management, and corporate actions.
Key Dates
- Deadline for Luxembourg market participants to complete the CSSF national competent authorities’ T+1 readiness survey
- Expected application date of revised ESMA guidelines on standardised procedures and messaging protocols and the aligned new RTS on Settlement Discipline requirements on allocations and confirmations
- Effective date for the transition to a T+1 settlement cycle in the EU under CSDR
Compliance Impact
Non‑compliance is high‑impact: failure to prepare for T+1, to respond adequately to supervisory surveys, or to align processes with RTS on Settlement Discipline and ESMA guidelines can lead to increased settlement fails, penalties, supervisory scrutiny, and potential enforcement action. The T+1 change also amplifies operational, liquidity, and conduct risks if firms cannot meet accelerated timelines, making early execution of remediation plans a prudential and conduct priority.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
BankBroker DealerAsset Manager Standard form for the notification of Home Member State
All Firms
No description available.
All Firms
No description available.
Asset ManagerAll Firms
No description available.
All Firms
No description available.
All Firms
amending Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region as well as Iran’s actions undermining freedom of navigation in the Middle East
All Firms
Situation as at 30 April 2026
Asset Manager
Situation as at 30 April 2026
All Firms
No description available.
The CSSF has formally repealed Circular IML 91/75 with immediate effect through the publication of Circular CSSF 26/912 on 22 May 2026. Compliance teams for Luxembourg UCIs and related structures must now ensure that no policies, procedures or prospectus provisions continue to rely on or reference IML 91/75, and instead rely on the current UCI, SIF, SICAR and EU fund law framework and subsequent CSSF circulars and administrative practice.
What Changed
- - Circular IML 91/75, which set out rules for Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment, is repealed in full with effect from 22 May 2026...
- All amendments to Circular IML 91/75 introduced by Circulars CSSF 05/177, 18/697, 21/790, 22/811 and 25/901 are implicitly repealed as part of the repeal of IML 91/75 itself.
- The regulatory expectations previously contained in IML 91/75 are now either superseded by later Luxembourg fund laws (including post‑1988 UCI legislation and regimes for SICARs and SIFs), later CSSF...
- The historical link to the Law of 30 March 1988 on undertakings for collective investment is effectively severed at circular level, confirming that the operative framework is now the modern suite of...
- IML 91/75 is flagged as archived by the CSSF as of 22 May 2026, clarifying that it has no continuing normative or interpretative value as a live supervisory instrument.
Suggested Considerations
- Identify and inventory all internal and external documents (including policies, procedures, compliance manuals, prospectuses, offering documents, service agreements and SLAs) that reference Circular IML 91/75 or its amending Circulars CSSF 05/177, 18/697, 21/790, 22/811 and 25/901.
- Remove or replace all references to Circular IML 91/75 and its amending circulars in compliance frameworks, manuals, registers of applicable rules and control libraries, ensuring they are mapped instead to the current applicable UCI, SIF, SICAR, AIFM and relevant CSSF circulars.
- Perform a gap analysis to confirm that all substantive topics previously governed by IML 91/75 in your framework are now fully covered by current Luxembourg laws, EU fund regulations and up‑to‑date CSSF circulars and FAQs.
- Update training materials and onboarding content for compliance, portfolio management, risk and operations staff to reflect that IML 91/75 has been repealed and to direct staff to the current legal and regulatory sources governing UCIs and alternative funds.
- Adjust internal audit and compliance monitoring programs so that any test steps or key controls referencing IML 91/75 are updated to reference the applicable current provisions and CSSF administrative practice.
Key Dates
- Original Circular IML 91/75 entered into force, setting rules for undertakings governed by the Law of 30 March 1988 on undertakings for collective investment
- Circular CSSF 26/912 is published and takes effect, repealing Circular IML 91/75 (as amended) with immediate effect and archiving it from the same date
Compliance Impact
The immediate compliance risk is moderate: there are no new obligations, but relying on a repealed circular can create legal uncertainty, documentation inconsistencies and supervisory challenges during CSSF inspections. Failure to update frameworks may weaken control design, lead to outdated disclosures and reduce credibility with the CSSF in the event of reviews or thematic inspections.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundBank ESMA Guidelines on stress test scenarios under Article 28 of the Money Market Fund Regulation – Update 2025 (ESMA50-481369926-30585)
Circular CSSF 26/911 informs Luxembourg money market fund (MMF) managers that the CSSF is integrating ESMA’s 2025 update of the stress test scenarios under Article 28 of the Money Market Fund Regulation (MMFR), and that these new ESMA Guidelines now form part of the Luxembourg supervisory expectations. The circular repeals and replaces Circular CSSF 25/877 as of 26 May 2026 and requires MMFs and their managers to apply the 2025 stress test parameters for MMF reporting from the reporting date 30 June 2026 onwards, driving immediate model, data, and reporting changes.
What Changed
- - Circular CSSF 26/911 replaces Circular CSSF 25/877 and integrates ESMA’s 2025 Guidelines on stress test scenarios under Article 28 of Regulation (EU) 2017/1131 (MMFR), making the updated scenarios...
- The 2025 ESMA Guidelines (Ref. ESMA50-481369926-30585) update the common reference stress test parameters for MMFs, reflecting more recent market conditions and liquidity risk drivers than the 2024...
- The circular clarifies that MMFs and MMF managers must use the updated 2025 ESMA stress test scenarios when preparing the MMF reporting required under the MMFR and the related Commission Implementing...
- Circular CSSF 26/911 confirms that the 2025 Guidelines and their translations, published by ESMA on 26 March 2026, are now integrated into CSSF supervisory practice, following the ESMA process...
- The circular reiterates that MMFs and their managers must tailor the ESMA reference scenarios to the specificities of each MMF, adding additional risk factors or requirements where needed to ensure...
Suggested Considerations
- Identify all MMFs and MMF mandates in scope of Regulation (EU) 2017/1131 for which the CSSF is the competent authority and confirm that they are currently using the 2024 ESMA stress test framework under Circular CSSF 25/877.
- Obtain and review in detail the ESMA 2025 Guidelines on stress test scenarios (ESMA50-481369926-30585) and the annexed parameters as integrated by Circular CSSF 26/911, comparing them line‑by‑line to the 2024 version to map all methodological and parameter changes.
- Update the MMF stress testing policy and procedures to reference Circular CSSF 26/911 and the 2025 ESMA Guidelines, including explicit descriptions of the scenarios, calibration choices, modelling techniques, and governance for scenario approval.
- Recalibrate stress testing models and tools used for MMFs to reflect the 2025 common reference parameters, ensuring that interest rate shocks, credit spread moves, liquidity shocks, redemption scenarios, and concentration risks are aligned with the new ESMA specifications.
- Perform impact analyses on representative MMFs using both 2024 and 2025 parameters to quantify changes in stress outcomes, and prepare internal briefing materials for senior management and boards explaining the impacts on liquidity and risk profiles.
Key Dates
- ESMA publishes the English, French, and German translations of the 2025 Guidelines on stress test scenarios under Article 28 MMFR on its website, starting the two‑month period to application
- Circular CSSF 26/911 enters into force and Circular CSSF 25/877 is repealed and replaced, making the 2025 ESMA Guidelines the applicable stress testing framework in Luxembourg
- MMFs and MMF managers must apply the 2025 ESMA Guidelines for the preparation of the required MMF reporting as from the reporting date 30 June 2026 onwards, meaning that stress test calculations underlying this and subsequent reports must be based on the 2025 parameters
Compliance Impact
Non‑compliance with Circular CSSF 26/911 and the integrated 2025 ESMA stress test Guidelines can lead to MMF reporting deficiencies, supervisory findings, and potential risk‑management remediation measures imposed by the CSSF, including expectations to strengthen liquidity and governance. Persistent or material breaches could contribute to more intrusive supervisory engagement, restrictions on MMF activities, or sanctions under the MMFR and Luxembourg supervisory framework.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerBankHedge Fund
No description available.
All Firms
1° amending:(a) the Law of 5 April 1993 on the financial sector, as amended;(b) the Law of 17 December 2010 relating to undertakings for collective investment, as amended;(c) the Law of 18 December 2015 on the failure of credit institutions and certain investment firms, as amended;(d) the Law of 15 March 2016 on OTC derivatives, central counterparties and trade repositories and amending different laws relating to financial services, as amended;2° transposing:(a) Directive (EU) 2024/1619 of th...
Bank
No description available.
Asset Manager
Situation as at 31 March 2026
BankAsset ManagerBroker Dealer
Situation from March 2025 to March 2026
BankAsset ManagerBroker Dealer
Situation from March 2025 to March 2026
BankAsset ManagerBroker Dealer
Situation from March 2025 to March 2026
Asset ManagerBankBroker Dealer
relating to the issue of covered bonds
BankWealth ManagerAll Firms
on markets in financial instruments
BankAsset ManagerBroker Dealer
on market abuse
BankBroker DealerAsset Manager transposing Directive 2004/25/EC of the European Parliament and of the Council of 21 April 2004 on takeover bids
BankBroker DealerAsset Manager
Application of the Guidelines of the European Securities and Markets Authority for the criteria on the assessment of knowledge and competence under the Markets in Crypto Assets Regulation (MiCA) (ESMA35-24871704-2922)
Circular CSSF 26/909 specifies how the CSSF applies ESMA's Guidelines (ESMA35-24871704-2922) for assessing **knowledge and competence** criteria under MiCA, targeting staff involved in crypto-asset services. It matters because it enforces MiCA's staff certification requirements, ensuring Luxembourg CASPs meet EU-wide standards for consumer protection and operational integrity amid the full MiCA rollout on 30 December 2024.
What Changed
- - Adoption of ESMA Guidelines: CSSF mandates application of ESMA's criteria for evaluating staff knowledge and competence in crypto-asset services, including roles in custody, trading, portfolio...
- Assessment Framework: Firms must implement standardized tests and processes to verify staff qualifications, aligning with MiCA Article 62 on CASP authorization, focusing on technical crypto...
- No New Standalone Rules: This circular builds on prior CSSF MiCA circulars (e.g., 25/890 on crypto-asset classification), integrating competence checks into licensing dossiers and ongoing supervision.
Suggested Considerations
- Assess Staff Competence: Implement ESMA-guided evaluations (e.g., exams, certifications) for all relevant personnel handling crypto services; document results in governance frameworks.
- Update Policies and Training: Integrate competence criteria into HR, onboarding, and annual reviews; roll out MiCA-specific training on reporting, breaches, and governance.
- Licensing Dossier Enhancement: Include competence attestations in CSSF applications; appoint dedicated compliance/risk officers with verified qualifications.
- Ongoing Monitoring: Conduct regular audits, penetration tests, and incident planning; confirm compliance annually via management body statements.
- Early CSSF Engagement: Schedule dialogues and info sessions; create MiCA readiness scorecards for board and regulator discussions.
Key Dates
Circular CSSF 26/909 published; immediate application of ESMA competence guidelines.; [User-provided content]
Compliance Impact
Urgency: High – With publication today (1 April 2026) and MiCA's CASP regime live since 30 December 2024, firms face immediate supervisory scrutiny during licensing and VASP transitions ending 1 July 2026. Non-compliance risks authorization denial, enforcement, or operational halts, especially as CSSF audits dossiers for competence gaps amid Luxembourg's role as MiCA hub.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Crypto ExchangeBankFintech Administrative sanction imposed on BigRep SE
The CSSF imposed a €20,000 administrative fine on BigRep SE on 1 April 2026 for failing to comply with a CSSF order to publish, disseminate, store on the Officially Appointed Mechanism (OAM), and file its half-yearly financial report as of 30 June 2025, under the Luxembourg Transparency Law of 11 January 2008. This sanction underscores CSSF's strict enforcement of periodic disclosure obligations for issuers with Luxembourg as their home Member State, signaling heightened supervisory scrutiny on timely reporting.
What Changed
This is not a regulatory change but an enforcement action under the existing amended Law of 11 January 2008 on transparency requirements for issuers (Transparency Law). Key requirements reiterated include Article 4 (obligation to publish half-yearly financial reports), effective dissemination, storage on the OAM, and filing with CSSF, with CSSF empowered under Article 25(1) to impose fines for non-compliance, considering circumstances per Article 26a. This follows a prior €10,000 fine on the same issuer on 12 January 2026 for initial failure to publish the same report.
Suggested Considerations
- Issuers must ensure timely publication of periodic financial reports (half-yearly per Article 4, annual per Article 3) via effective dissemination, OAM storage (e.g., Luxembourg Stock Exchange systems), and CSSF filing.
- Respond promptly to any CSSF orders or injunctions to avoid escalated fines.
- Implement robust internal controls for reporting calendars, including automated reminders and pre-verification processes.
- Review and file any overdue reports immediately upon CSSF notification.
Key Dates
- Reference date for BigRep SE's half-yearly financial report that was not published
- Date of initial €10,000 fine for failure to publish the report
- Date of €20,000 fine for non-compliance with CSSF order on report dissemination, OAM storage, and CSSF filing
- Deadline to lodge appeal with the Tribunal administratif (three months from 1 April 2026 sanction, per Article 27)
Compliance Impact
Urgency: Medium – This enforcement highlights CSSF's proactive verification of disclosures and willingness to impose escalating fines (€10k initial, €20k for non-response, up to €40k in similar cases), but applies to specific non-compliance rather than new rules. It matters for Luxembourg-domiciled issuers as it demonstrates low tolerance for delays, potentially increasing audit focus on reporting processes and reputational risk from public sanctions.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
All Firms
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].
- 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,...
- Emphasis on detailed documentation of mandates to demonstrate fitness, properness, and avoidance of conflicts, including for shareholders with qualifying holdings.
- No entirely new requirements introduced, but the update likely incorporates evolving governance expectations, such as enhanced delegate oversight and AML/CFT compliance officer designations.
Suggested Considerations
- Download and use the XLSX table: Incorporate the exact list of activities/mandates into internal templates for reporting management body and conducting officer roles[Source URL].
- Update authorization and notification files: Include detailed CVs, criminal record extracts, wealth declarations, and organization charts for relevant personnel/shareholders; notify CSSF of changes (e.g., qualifying holdings, guarantees).
- Conduct fit-and-proper assessments: Ensure declarations cover all listed mandates, demonstrating no conflicts and adequate resources; perform initial/ongoing due diligence on delegates.
- Annual compliance review: Document roles in compliance monitoring plans, training, and reporting to senior management/CSSF; align with delegate oversight (e.g., risk-based monitoring of compliance, audit functions).
- Policy updates: Revise governance policies to reflect the updated list, including AML/CFT officer designations and own funds proofs.
Key Dates
- Publication of underlying Circular CSSF 18/698, setting baseline requirements
- Original publication of the list
- Latest update to the list, requiring immediate review and integration into reporting processes[Source URL]
financial year); - Compliance deadline for Circular 18/698 obligations, including governance reporting (e.g., 5 months after year-end)
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).
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerBankAll Firms
Situation as at 28 February 2026
BankAsset ManagerBroker Dealer
Administrative sanction imposed on an investment firm
The CSSF imposed an administrative sanction on 8 October 2025 against an unnamed investment firm, as detailed in a publication released on 4 March 2026. This enforcement action underscores CSSF's rigorous oversight of investment firms, particularly in areas like AML/CFT compliance, conduct rules, and organizational requirements, serving as a warning for similar entities to strengthen cooperation and internal controls. It matters because it highlights escalating fines for repeated or material breaches, potentially influencing supervisory expectations across Luxembourg's financial sector.
What Changed
- No new regulatory changes or requirements are introduced; this is an enforcement action applying existing rules.
- Failure to cooperate with CSSF requests, e.g., not submitting required AML/CFT questionnaires by deadlines, violating Article 5(1) of the amended Law of 12 November 2004 on AML/CFT.
- Non-compliance with investment policies, organizational requirements, or conduct rules under the UCI Law (e.g., Articles 41, 43, 109), including improper broker exposures or valuation failures.
- These reflect ongoing enforcement of established frameworks like the AIFM Law, UCI Law, and AML/CFT Law, with fines calibrated by factors like breach duration, firm size, cooperation level, and prior...
Suggested Considerations
- Enhance cooperation protocols: Implement automated tracking for CSSF requests (e.g., questionnaires) with escalations for reminders; document all responses.
- Review investment compliance: Audit broker exposures, valuation processes, and subscription/redemption controls against UCI Law Articles 41-43, 109; suspend dealings if uncertainties arise.
- Strengthen governance: Conduct gap analyses on internal controls, risk assessments, and reporting for depositary/oversight functions per AIFM Law Article 19(9) and CDR 231/2013.
- Training and monitoring: Roll out firm-wide training on AML/CFT obligations (Article 5(1)) and perform reconciliations of assets/records; prepare for on-site/off-site CSSF inspections.
- Self-reporting: Proactively disclose prior breaches to mitigate fine severity.
Key Dates
- Date of prior depositary oversight fine
- Deadline for submitting CSSF AML/CFT Questionnaire (breach example from similar case)
- Date of fine imposition for UCITS investment policy breaches
- Date of fine imposition in comparable AIFM non-cooperation case
- Date of the sanction in question
Compliance Impact
Urgency: High - This matters due to CSSF's pattern of publicizing nominative sanctions (e.g., Max Gain Capital, Zeus Asset Management), signaling increased scrutiny on investment firms amid AML/CFT and conduct risks. Fines (EUR 10,000–127,500) represent material hits (up to 10% of turnover), with factors like poor cooperation amplifying penalties; firms with similar exposures face elevated inspection risk, especially post-2025 enforcement wave.
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerBroker DealerWealth Manager
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
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.
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...
- 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...
- Quarterly public disclosure: Investment Fund Managers (IFMs) must now publish detailed portfolio holdings to all investors at least quarterly with a maximum time lag of 30 business days (previously...
Suggested Considerations
- *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
- CSSF publishes updated FAQ (effective immediately)
- Firms should implement changes promptly to ensure compliance with the new quarterly disclosure requirement
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
Asset Manager
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
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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
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).
Suggested Considerations
- Conduct immediate gap analysis: Review safekeeping processes for ownership verification (Article 19(8)(b) AIFM Law), ensuring transaction documentation, segregated account proofs, and full holding chain records are available at transaction points.
- Enhance oversight duties: Implement risk assessments per Article 92(1) CDR 231/2013, valuation compliance checks (Article 94), and cash remittance monitoring (Article 96); appoint delegates with due diligence.
- Strengthen governance: Update internal controls, procedures, and conflict-of-interest policies (e.g., director overlaps); ensure key documentation availability and evidence of controls.
- Firm-wide audit: For repeat offenders like Corestate, perform root-cause analysis on prior sanctions and submit remediation plans to CSSF if inspected.
- Training and reporting: Train staff on CSSF expectations; improve cooperation mechanisms to avoid AML/CFT fines for non-submission of requests.
Key Dates
- Prior administrative sanction imposed on Corestate Capital Holding S.A., indicating ongoing non-compliance issues
- Publication date of the current administrative sanction on Corestate Capital Holding S.A., effective immediately as a public enforcement notice
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.
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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...
Suggested Considerations
- Conduct immediate gap analysis on depositary functions: Verify ownership chains, transaction documentation, segregated account reconciliations, and custodian delegations per AIFM Law Articles 19(8) and 19(11).
- Enhance oversight processes: Implement risk assessments for AIF strategies, valuation policy checks, and cashflow monitoring per CDR 231/2013 Articles 92, 94, and 96.
- Strengthen governance: Review internal controls, procedures, and conflicts (e.g., director overlaps with affiliates); ensure availability of control evidence.
- For issuers like Corestate: Confirm compliance with half-yearly financial reporting and dissemination under Transparency Law Article 4.
- Firm-wide: Perform mock CSSF on-site inspections focusing on 2022-2025 periods, given inspection timelines in recent cases.
Key Dates
- Prior administrative sanction imposed on Corestate Capital Holding S.A
- 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.
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No description available.
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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.
Suggested Considerations
- *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
- FAQ Version 7 effective date; MiCAR compliance requirements become operative
- Deadline for Virtual Asset Service Providers (VASPs) to transition from registration to authorization under MiCAR or cease operations
Compliance Impact
Urgency: HIGH
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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.
Suggested Considerations
- *Immediate Compliance Steps:
- *Portfolio Audit: Conduct a comprehensive review of all UCITS and AIF holdings to identify current and potential crypto-asset exposures, both direct and indirect (including derivatives with crypto underlyings).
- *Investment Policy Updates: Revise fund documentation, prospectuses, and investment policies to reflect the 10% NAV limits and MiCAR compliance requirements.
- *Risk Management Assessment: Update risk management policies to address crypto-asset volatility, liquidity, and technological risks, with case-by-case impact assessments on fund risk profiles.
- *Investor Notification: Ensure transparent and timely communication with investors regarding any crypto-asset investments or policy changes.
Key Dates
- FAQ Version 7 effective date (entry into force of MiCAR alignment)
- Deadline for Virtual Asset Service Providers (VASPs) to transition to CASP authorization or cease operations
- 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
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The CSSF informs the market regarding the outcomes of the SFTR Data Quality indicators review performed in 2025
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Press release 26/02
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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...
- Taxonomy Disclosures Amendment: On 4 July 2025, the European Commission adopted a Delegated Act amending the Taxonomy Disclosures as part of the Omnibus package, affecting Article 8 of the Taxonomy...
- Double Materiality Assessment (DMA) Focus: The CSSF emphasized the importance of issuers not only disclosing the results of their DMA but also explaining the process itself, including granular...
Suggested Considerations
- *Financial Information (IFRS):
- *Enhanced Note Disclosures: Provide sufficient disaggregation and additional information in financial statement notes for material amounts and variances, particularly where information is not presented on the face of primary statements. The CSSF emphasizes compliance with paragraph 112(c) of IAS 1.
- *Cash Flow Statement Presentation: Ensure cash flows are presented on a gross basis (not net), exclude non-cash transactions, and disclose restricted cash balances with accompanying management commentary as required by paragraph 48 of IAS 7.
- *Segment Reporting Completeness: Clearly disclose all income and expense items in segment reporting, even when not separately provided to or reviewed by the Chief Operating Decision Maker (CODM), if they are included in reported segment results.
- *Going Concern Assessment: Maintain high transparency regarding accounting policies and judgments applied when classifying going concern assumptions.
Key Dates
- CSSF published enforcement priorities press release for FY2024 reporting
- European Commission adopted Delegated Act amending Taxonomy Disclosures (Omnibus package)
- CSSF published full results of fact-finding exercise on ESRS reporting
- CSSF published enforcement results report (current publication)
Compliance Impact
Urgency: HIGH
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original CSSF source
before acting. Full disclaimer.
All Firms
Administrative sanction imposed on BigRep SE
The CSSF imposed a €10,000 administrative fine on BigRep SE on 12 January 2026 for failing to publish its half-yearly financial report as of 30 June 2025, as required under Article 4 of Luxembourg's Transparency Law of 11 January 2008 (as amended). This enforcement action underscores the CSSF's rigorous supervision of periodic disclosure obligations for issuers with Luxembourg as their home Member State, serving as a reminder of the consequences for non-compliance with transparency requirements. Compliance professionals should note this as evidence of ongoing CSSF scrutiny on timely reporting, with potential fines scaled based on circumstances per Article 26a.
What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the Transparency Law of 11 January 2008 (as amended), specifically Article 4, which mandates issuers to publish half-yearly financial reports, including effective dissemination, storage on the Officially Appointed Mechanism (OAM), and filing with the CSSF. No new rules are introduced; the sanction reinforces the unchanged deadlines and processes for periodic information publication, with the CSSF acting under Article 25(2) as the competent authority.
Suggested Considerations
- Issuers: Immediately review internal processes for half-yearly financial reporting to ensure compliance with Article 4, including timely publication, OAM storage, and CSSF filing; conduct gap analyses against Transparency Law deadlines.
- All affected parties: Implement or enhance monitoring calendars for periodic disclosures, with automated alerts for period-ends like 30 June; perform mock filings to test dissemination and storage mechanisms.
- BigRep SE specifically: Consider appeal to Tribunal administratif within 3 months if contesting the fine; remediate the specific non-compliance by publishing the overdue report if not already done.
- wide actions are mandated beyond general adherence, but proactive audits are advisable given CSSF's supervisory focus.
Key Dates
- Period-end date for the required half-yearly financial report that BigRep SE failed to publish
- Date of administrative sanction imposition by CSSF and publication of the decision
(i.e., by 12 April 2026) - Deadline for BigRep SE to lodge a court action with the Tribunal administratif against the sanction, per Article 27 of the Transparency Law
Compliance Impact
Urgency: Medium – This matters as a specific enforcement example in CSSF's ongoing verification of periodic information publication, signaling heightened scrutiny rather than a systemic shift. While the €10,000 fine is modest, it demonstrates fines for even isolated breaches (scaled per Article 26a), potentially escalating for repeats; firms should prioritize reporting calendars to avoid reputational harm and publication of sanctions under Article 26b(1).
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All Firms
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...
- Borrowing Limits: New limits for SIFs/Part II UCIs (e.g., 70% of net assets, excluding temporary borrowings tied to commitments); tailored by investor type.
- Enhanced Disclosures: Offering documents must detail investment policies, risks (especially private equity for retail), subscription/redemption processes, liquidity tools, gates, and amendment...
- SICAR Risk Capital: Modernizes definition to include equity, loans, bonds, mezzanine; clarifies direct/indirect investments with three cumulative elements (risk of total loss, no redemption rights,...
Suggested Considerations
- Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e.g., gates, notice periods), redemption processes, and investor-specific warnings.
- 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.
- For SICARs: Ensure risk capital investments meet modernized criteria; apply look-through for limits.
- Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance.
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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original CSSF source
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Rules applicable to undertakings for collective investment when they employ certain techniques and instruments relating to transferable securities and money market instruments
Circular CSSF 08/356, as amended by Circular CSSF 25/901, establishes detailed rules for Luxembourg undertakings for collective investment (UCIs), including UCITS and alternative investment funds (AIFs), on the use of techniques and instruments relating to transferable securities and money market instruments, such as securities lending, repo transactions, and over-the-counter (OTC) derivatives. It matters because it ensures investor protection, risk management, and market stability by imposing strict eligibility, collateral, and operational requirements, aligning Luxembourg funds with EU standards under UCITS and AIFMD directives. Compliance is critical for Luxembourg-domiciled funds engaging in these activities to avoid regulatory sanctions and operational disruptions.
What Changed
- The original Circular CSSF 08/356 (2008) transposed UCITS III requirements on eligible techniques like securities lending and repos.
- Expanded collateral rules: Collateral must now include sustainable assets meeting SFDR criteria, with daily marking-to-market and haircuts adjusted for liquidity and credit risk (Section 3).
- Counterparty exposure limits: Net exposure to a single OTC counterparty capped at 10% of net asset value (NAV), down from previous thresholds in some cases, with mandatory collateralization (Section...
- Operational safeguards: Mandatory use of triparty agents for repos, enhanced segregation of collateral, and annual stress testing disclosures (Section 5, as amended).
- Reporting enhancements: Quarterly reports to CSSF on transaction volumes, risks, and revenues from these activities (Annex 1, updated).
These align with ESMA guidelines (e.g., ESMA/2012/832 on OTC...
Suggested Considerations
- *Policy Review & Update: Revise fund prospectuses, KIIDs, and risk management policies to reflect amended limits (e.g., counterparty caps, ESG collateral) within 3 months of 01 January 2026.
- *Risk Management Systems: Implement or upgrade systems for daily collateral valuation, stress testing, and exposure monitoring; conduct gap analysis against Section 4 requirements.
- *Counterparty Due Diligence: Reassess OTC counterparties for eligibility (e.g., EMIR clearing thresholds); negotiate ISDA/CSA agreements with updated haircuts.
- *Operational Setup: Appoint triparty agents where required; ensure collateral segregation complies with Section 5.
- *Reporting & Disclosure: Prepare for new quarterly CSSF filings (template in Annex 1); disclose revenues/reinvestments from techniques in annual reports (Article 14 UCITS Law).
Key Dates
- Original Circular CSSF 08/356 effective date for UCITS III implementation
- Partial updates for UCITS IV alignment
- Extension to AIFs under AIFMD transposition
- Issuance of amending Circular CSSF 25/901
- Effective date for amendments (e.g., new collateral rules, reporting formats)
Compliance Impact
Urgency: High - Immediate relevance for funds actively using these techniques (common in fixed-income and equity strategies for yield enhancement). Non-compliance risks CSSF fines (up to 5% of NAV), temporary prohibitions on techniques, or fund suspension. With the 01 January 2026 effective date recently passed (as of current context), firms face heightened scrutiny in 2026 reporting cycles; proactive remediation avoids enforcement actions amid CSSF's focus on operational resilience.
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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,...
- 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...
Suggested Considerations
- Notifications: Submit initial branch/FOPS notification to home authority (including operational programme); notify changes (e.g., services, locations) at least one month in advance to both home authority and CSSF.
- Reporting: Complete and sign SAQ (accurate, concise, true/fair view) via eDesk within six months post-year-end; provide REA-appraised AML/CFT and conduct reports, detailing branch procedures/controls.
- Supervision cooperation: Facilitate home/CSSF on-site inspections (with professional secrecy guarantees); ensure branch compliance with Luxembourg laws (e.g., LFS Article 46(2)).
- Ongoing: Maintain branch infrastructure, update for legal changes, and align with CSSF user guides for eDesk authentication.
Key Dates
- 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)
- Home state authority communicates notification file to CSSF for branch/FOPS establishment
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...
- 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 Clarification
- The circular applies to credit institutions whose head office is in another EU Member State and to investment firms of EU origin established in Luxembourg by way of branches or exercising activities...
Suggested Considerations
- *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
- Circular CSSF 25/898 published by the CSSF
- Related modernization framework (Circular CSSF 25/901) entered into force for Part II UCIs, SIFs, and SICARs
- Institutions should align their SAQ responses and compliance documentation with the updated framework immediately upon publication
Compliance Impact
Urgency: HIGH
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original CSSF source
before acting. Full disclaimer.
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