Repeal of Circular IML 91/75

What Changed

• - Circular IML 91/75, which set out rules for Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment, is repealed in full with effect from 22 May 2026 by Circular CSSF 26/912.
• All amendments to Circular IML 91/75 introduced by Circulars CSSF 05/177, 18/697, 21/790, 22/811 and 25/901 are implicitly repealed as part of the repeal of IML 91/75 itself.
• The regulatory expectations previously contained in IML 91/75 are now either superseded by later Luxembourg fund laws (including post‑1988 UCI legislation and regimes for SICARs and SIFs), later CSSF circulars, or absorbed into the CSSF’s non‑codifie
• The historical link to the Law of 30 March 1988 on undertakings for collective investment is effectively severed at circular level, confirming that the operative framework is now the modern suite of UCI and AIFM-related laws and regulations.
• IML 91/75 is flagged as archived by the CSSF as of 22 May 2026, clarifying that it has no continuing normative or interpretative value as a live supervisory instrument.
• Circular CSSF 26/912 acts as a pure repeal / housekeeping circular rather than introducing new substantive conduct, prudential or reporting requirements, but it requires firms to align all documentation and internal references with the current framew

Suggested Considerations

• Identify and inventory all internal and external documents (including policies, procedures, compliance manuals, prospectuses, offering documents, service agreements and SLAs) that reference Circular IML 91/75 or its amending Circulars CSSF 05/177, 18/697, 21/790, 22/811 and 25/901.
• Remove or replace all references to Circular IML 91/75 and its amending circulars in compliance frameworks, manuals, registers of applicable rules and control libraries, ensuring they are mapped instead to the current applicable UCI, SIF, SICAR, AIFM and relevant CSSF circulars.
• Perform a gap analysis to confirm that all substantive topics previously governed by IML 91/75 in your framework are now fully covered by current Luxembourg laws, EU fund regulations and up‑to‑date CSSF circulars and FAQs.
• Update training materials and onboarding content for compliance, portfolio management, risk and operations staff to reflect that IML 91/75 has been repealed and to direct staff to the current legal and regulatory sources governing UCIs and alternative funds.
• Adjust internal audit and compliance monitoring programs so that any test steps or key controls referencing IML 91/75 are updated to reference the applicable current provisions and CSSF administrative practice.
• Communicate internally to relevant stakeholders (legal, compliance, portfolio management, product development and operations) that IML 91/75 is archived and no longer to be cited as a current regulatory authority in decision-making or client communications.

Key Dates

Who is Affected