Update of the CSSF FAQ concerning the Luxembourg Law of 17 December 2010 with regard to the portfolio transparency requirements for UCITS ETFs and the holding of ancillary liquid assets
AI Analysis
The CSSF has updated its FAQ on portfolio transparency requirements for UCITS ETFs, relaxing disclosure frequency from monthly to quarterly publication of detailed holdings while maintaining daily information sharing with market makers and authorized participants. This change aligns Luxembourg's regulatory framework more closely with Ireland's semi-transparent ETF approach and is designed to attract active asset managers to the Luxembourg domicile by reducing proprietary information exposure.
Key dates
- 17 February 2026
- - CSSF publishes updated FAQ (effective immediately)
- No explicit transition period stated Deadline
- - Firms should implement changes promptly to ensure compliance with the new quarterly disclosure requirement
Suggested considerations
- *For IFMs Managing UCITS ETFs:
- *Update disclosure procedures to transition from monthly to quarterly publication schedules for detailed portfolio holdings
- *Maintain daily information sharing with APs and market makers to support arbitrage mechanisms—this requirement remains unchanged
- *Revise prospectuses to reflect the new quarterly disclosure frequency and confirm compliance with the 30 business-day publication window
- *Document procedures for calculating the 30 business-day deadline from quarter-end
- *Establish systems to ensure non-discriminatory access to quarterly holdings data for all investors
What changed
- The update modifies two critical FAQ sections: Portfolio Transparency Requirements (Question 12.1) The CSSF has expanded and clarified its guidance to apply to all UCITS ETFs, not just actively managed ones. The key modification establishes a two-t
- Daily disclosure to market participants: Market makers and authorized participants (APs) continue to receive detailed portfolio information on a daily basis to maintain efficient arbitrage mechanisms and active secondary markets.
- Quarterly public disclosure: Investment Fund Managers (IFMs) must now publish detailed portfolio holdings to all investors at least quarterly with a maximum time lag of 30 business days (previously monthly with one-month lag). Ancillary Liquid Asset
Compliance impact
Urgency: HIGH
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
What the CSSF said
No description available.
Published by CSSF . Read the full notice at the source for the authoritative text.