FAQ Crypto-Assets – Undertakings for collective investment (Updated)
Executive Summary
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. However, AIFs may invest directly and indirectly in crypto-assets under MiCAR's scope, provided such investments do not prevent compliance with existing regulatory requirements. Authorization Requirements for Elevated Exposures Any AIFM intending to manage an AIF investing in crypto-as
What You Need To Do
- *Immediate Compliance Steps
- *Portfolio Audit
- *Investment Policy Updates
- *Risk Management Assessment
- *Investor Notification
- *CSSF Notification
Key Dates
Compliance Impact
Urgency Rating: HIGH
Who is Affected
Summary
Version 7 – 04/02/2026