Circular CSSF 25/900
Executive Summary
Circular CSSF 25/900, issued on 16 December 2025, amends Circular CSSF 22/811 to clarify governance principles, authorisation requirements, and operational standards for UCI (Undertakings for Collective Investment) administrators in Luxembourg, while reforming annual reporting obligations. It matters because it strengthens supervisory oversight, aligns with DORA for ICT outsourcing, and simplifies reporting to enhance efficiency and compliance in the fund administration sector. #
What Changed
- Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses governance, internal controls, operational organization, and risk management; detailed instructions are now on the CSSF website. - Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authorisation remains valid unless substantial changes occur, requiring re-application or prior notification. - Clarifies scope for eligible entities (e.g., UCIs, IFMs, management companies under Luxembourg law) performing one or more of three UCI administration functions (defined in point 10); mandate
What You Need To Do
- Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations
- Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025
- Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750)
- For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882
Key Dates
Compliance Impact
Urgency: High - Immediate repeal of prior reporting Annex requires prompt process updates; new framework applies to FY 2025 year-ends (just past as of Jan 2026), risking supervisory scrutiny or penalties for non-compliance; DORA alignment adds operational resilience pressure amid ongoing CSSF focus on fund admin governance.
Who is Affected
Summary
amending Circular CSSF 22/811.Authorisation and organisation of entities acting as UCI administrators.