Guidance on the documents and information to be submitted for the assessment of the shareholding structure of authorised IFMs – initial authorisation and modification of an authorised IFM (qualified and non-qualified shareholders)
Executive Summary
This CSSF guidance (Version 1.0, published 2 March 2026) specifies the minimum documents and information required for assessing shareholding structures of authorised Investment Fund Managers (IFMs) during initial authorisation or modifications involving qualified and non-qualified shareholders. It standardises submissions to ensure completeness, with incomplete applications rejected until fully provided, enhancing regulatory efficiency and scrutiny of ownership changes. Compliance professionals must prioritise this to avoid delays in authorisation processes for Luxembourg-domiciled IFMs. #
What Changed
- Minimum Document Lists: Introduces detailed checklists in an XLSX format covering candidate shareholder documents (e.g., ID, CV, declarations of honour (DH), criminal records (CR) for natural persons; similar for legal persons, beneficial owners, and legal arrangements like trusts). - Differentiation by Shareholder Type: Requirements vary by natural/legal person, beneficial owner, direct/indirect qualified/unqualified shareholders, and involvement in financing (e.g., "Yes, if PEP or if requested by the CSSF" for beneficial owners; full docs for trustees in legal arrangements). - Other Mandatory Submissions: For qualified holding changes (entry, increase/decrease, removal), requires updated group structure charts, Market Entry Forms (MEF), financing details, and fee forms; prior CSSF auth
What You Need To Do
- Prepare Complete Packages
- Submit Core Items
- Initial/Modification Filings
Key Dates
Compliance Impact
Urgency: High – Immediate effect from 2 March 2026 means any ongoing or planned IFM authorisation/modification applications risk delays or rejection if non-compliant, potentially disrupting fund launches or ownership restructurings in Luxembourg's key investment management hub. Matters due to standardised scrutiny on fit-and-proper ownership, aligning with AIFMD governance and reducing administrat
Who is Affected
Summary
Version 1.0