Governance

CSSF publishes guidance on documents required to assess the shareholding structure of authorised IFMs

The CSSF has published a new guidance document setting out the minimum documents and information that authorised IFMs must submit when the regulator assesses their shareholding structure, whether for initial authorisation or for any subsequent change involving qualified or non‑qualified shareholders.

The CSSF stresses that any application missing one or more required items will be considered incomplete, and no regulatory review will commence until a full set of documents has been received. The CSSF may also request additional information if needed.

The new guidance (XLSX checklist) is available via the link provided by the CSSF.

This guidance reinforces the CSSF’s increasingly formalistic approach to ownership assessments and is likely to impact transaction timelines where changes in shareholding are involved.

Regulatory update: the Netherlands

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