UCI Reports foreseen by Circular CSSF 21/790 for year-ends 31 January 2026, 28 February 2026, 31 March 2026 and 30 April 2026 now available on eDesk and information on main updates
Executive Summary
This CSSF communiqué announces the availability of updated UCI Reports (SAQ, SR, and ML) under Circular CSSF 21/790 on the eDesk platform's CISERO module for specific 2026 year-ends, with key enhancements focused on valuation, NAV determination, and risk-based streamlining. It matters for Luxembourg UCIs as it reflects evolving supervisory priorities, aligns with EU directives like Directive (EU) 2024/927, and imposes refined self-assessment obligations to bolster resilience in stressed conditions and liquidity management. #
What Changed
- - SAQ Updates (Valuation Section): New questions on valuation policies for stressed market conditions/exceptional circumstances; coverage for new sub-funds/strategies; independent validation of material valuation models; and risk-based backtesting fo
- SAQ Simplifications and Clarifications: Removed questions on sub-funds with significant non-standard OTC derivatives, unquoted assets, or external valuer OTC FDIs (including NAV proportions); refined wording on conflicts of interest; added sub-questi
- SAQ NAV Determination: Updated Liquidity Management Tools (LMTs) sub-section to align with Annexes of AIFM/UCITS Review Directive (Directive (EU) 2024/927); added question on compliance with ESMA guidelines on performance fees (ESMA34-39-992).
- SR Streamlining: Removed procedures in investment compliance (e.g., eligibility assessments for closed-ended funds, structured instruments, non-plain vanilla OTC derivatives; credit quality for money market funds); removed NAV LMT policy checks (anti
- Reports for year-ends after 30 April 2026 available three months prior.
Suggested Considerations
- Access updated Reports on eDesk CISERO module immediately and review changes vs. 31 December 2025 versions.
- Update valuation policies/procedures to explicitly cover stressed conditions, new sub-funds/strategies, model validations, and backtesting; document compliance.
- Revise NAV processes for LMT alignment with Directive (EU) 2024/927 Annexes and ESMA performance fee guidelines; confirm for open-ended UCIs.
- Dirigeants/management: Complete/validate SAQ addressing new/clarified questions; prepare for REA SR/ML review.
- REAs: Perform streamlined SR procedures; issue ML on prior weaknesses with remediation timelines.
- Train staff on updates; conduct gap analysis on policies (e.g., stale valuations, conflicts); retain evidence for supervisory review.
Key Dates
Compliance Impact
Urgency: High – Immediate access required for imminent submissions (e.g., 31 January 2026 year-end due ~June 2026); new valuation questions demand policy reviews to avoid supervisory findings, especially amid stressed markets; SR simplifications reduce burden but shift focus to SAQ self-assessment, heightening dirigeants' accountability. Non-compliance risks CSSF follow-up on modified audits or we
Who is Affected
References
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Summary
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