Circular CSSF 26/912
Executive Summary
The CSSF has issued Circular CSSF 26/912, formally repealing Circular IML 91/75 (and its amendments) governing Luxembourg UCIs under the (now repealed) Law of 30 March 1988 on undertakings for collective investment. This is a technical clean‑up measure that removes an obsolete circular from the rulebook and confirms that the 1991 governance, organisational and investment rules under IML 91/75 no longer apply.
What Changed
- - Circular IML 91/75, including its amendments by Circulars CSSF 05/177, 18/697, 21/790, 22/811 and 25/901, is formally repealed by Circular CSSF 26/912.
- The rules on “revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment are subject” no longer form part of the active CSSF regulatory framework.
- Supervisory expectations for Luxembourg UCIs are now to be derived exclusively from the current UCI regime (notably the Law of 17 December 2010 relating to undertakings for collective investment and subsequent CSSF circulars and regulations), rather
- Any internal compliance mappings, policy references, or control frameworks that still cite Circular IML 91/75 or its amending circulars must be treated as referencing repealed guidance and should be updated to current rules.
Suggested Considerations
- Update your regulatory inventory and obligation registers to reflect that Circular IML 91/75 and its amending circulars (CSSF 05/177, 18/697, 21/790, 22/811 and 25/901) have been repealed by Circular CSSF 26/912 as of 22 May 2026.
- Verify that your compliance monitoring programmes and internal audit test plans do not rely on requirements sourced from Circular IML 91/75, and re-align any such tests to the currently applicable legal and regulatory standards.
- Communicate the repeal of Circular IML 91/75 internally to legal, compliance, risk, product, and fund administration teams to prevent continued reliance on obsolete rules in ongoing or future projects.
- For any ongoing remediation, authorisation or approval processes that previously cited IML 91/75 as justification for a control design, reassess and document those controls against the current CSSF requirements that have effectively replaced or superseded the 1991 framework.
- Maintain an audit trail evidencing the update of documentation and registers in response to Circular CSSF 26/912, including board or senior management notification where your governance framework requires it for changes in regulatory obligations.
Key Dates
Compliance Impact
The immediate compliance risk is low, as the circular repeals an already outdated framework; however, continuing to reference or rely on Circular IML 91/75 could create documentation inconsistencies, misalignment with current CSSF expectations and weaknesses in regulatory audits or inspections.
Who is Affected
References
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Summary
Repeal of Circular IML 91/75 related to the 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