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)

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, a
• 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;
• 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 authorisation mandatory.
• Enforcement Mechanism: From 2 March 2026, incomplete submissions halt analysis until remedied; CSSF may request additional info.

Suggested Considerations

• Prepare Complete Packages: For each new shareholder candidate, compile type-specific docs (e.g., ID/CV/DH/CR for direct unqualified shareholders; financing proof if indirect qualified lacks resources).
• Submit Core Items: Always include updated group structure chart, MEF (template available), acquisition financing details, fee form; classify request type (e.g., prior authorisation for qualified changes).
• Initial/Modification Filings: Use XLSX guidance as checklist; ensure beneficial owner verification per Circular CSSF 19/732.
• Ongoing: Notify CSSF of changes; anticipate ad-hoc requests for extras like PEP declarations.

Key Dates

Who is Affected