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Circular CSSF 19/708 - Annex (Updated)

AI Analysis

Executive Summary

Circular CSSF 19/708 mandates the electronic transmission of specified documents to the CSSF via secure platforms like e-file or SOFiE, effective from February 1, 2019, replacing prior paper or other methods. This updated annex (as amended by Circular CSSF 21/790 and further revisions up to April 1, 2025) standardizes submissions for investment funds and related entities, reducing administrative burdens while ensuring document integrity and CSSF accessibility. Compliance professionals must monitor the dynamic annex list on the CSSF website to avoid nullified submissions. #

What Changed

- Mandatory Electronic-Only Submission: Documents listed in Annex I must be transmitted exclusively via e-file (http://www.e-file.lu) or SOFiE (http://www.cetrel-securities.lu/wp_static/what-do-we-offer/secured-reporting-channel-sofie-sort/), in PDF format supporting read access, printing, copy/paste, and word search; other methods post-February 1, 2019, are null and void. - Dynamic Annex Updates: The annex, published on the CSSF website, is regularly updated (e.g., latest noted April 1, 2025) and includes prospectuses, management regulations, annual reports, risk management reports, compliance reports, and more, with specific nomenclatures required for each. - Scope Expansion: Extends beyond UCIs to securitisation undertakings (2004 Law), pension funds (2005 Law), SICARs, and Luxembourg I

What You Need To Do

  • Register/access e-file or SOFiE platforms if not already (test/production environments available since February 2019)
  • Consult and adhere to the latest Annex I for document list, nomenclatures, and formats (PDF with full functionality)
  • Ensure submissions are final/official versions matching hard copies; use specified identifiers for UCIs/SIFs/SICARs
  • Implement processes for automatic/manual transmission (e
  • Train staff on responsibilities and integrate into reporting workflows; reference CSSF FAQs for closing documents

Key Dates

1 February 2019 - Entry into force Mandatory electronic transmission for listed documents; non-electronic submissions null and void.
28 January 2019 - Publication date of original Circular CSSF 19/708.
22 December 2021 - Amendment by Circular CSSF 21/790.
1 April 2025 - Latest annex update noted.
Ongoing - Regular checks required Entities must monitor CSSF website for annex updates. DEADLINE

Compliance Impact

Urgency: Low (for new implementations post-2019; medium for ongoing monitoring). This matters for operational efficiency and CSSF relations, as non-compliance risks rejected filings, delays (e.g., approvals under SFDR processes), or supervisory scrutiny, but long-standing rule (since 2019) with established platforms reduces immediate pressure. Firms must prioritize annex vigilance to avoid disrupt

Who is Affected

Investment fund managers (IFMs) under Luxembourg law.Luxembourg undertakings for collective investment (UCIs), including management companies, UCITS, SIFs, SICARs.Securitisation undertakings (Law of 22 March 2004).Pension funds, SEPCAVs, and ASSEPs (Law of 13 July 2005).Any entities or interveners participating in their functioning (e.g., service providers submitting on behalf).

Summary

Electronic transmission of documents to the CSSF

Relevant Firm Types

Asset ManagerWealth ManagerInsuranceAll Firms
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