Virtual assets

On 4 February 2026, the CSSF published Version 7 of its FAQ on Crypto‑Assets for Undertakings for Collective Investment, reflecting a general update of the document following the entry into force of the Markets in Crypto‑Assets Regulation (MiCAR) and replacing previous references to “virtual assets” with the terminology of “crypto‑assets”.

For AIFs, direct and indirect investments in crypto‑assets falling under MiCAR are permitted, but according to current CSSF administrative practice AIFs open to retail investors other than well‑informed investors are subject to a 10% NAV cap. IFMs managing AIFs investing more than 10% of NAV in crypto‑assets must obtain the dedicated “Other–Other Fund–Crypto‑assets” authorisation and provide detailed information to the CSSF, including updated risk and valuation policies, custody arrangements and AML/CFT analysis. Where AIFs invest via target funds with crypto‑asset exposure, a fund‑of‑funds authorisation may be required, and IFMs must assess the target manager’s ability to manage crypto‑asset risks.

Crypto‑asset investments materially increase exposure to ML/TF and proliferation financing risks. RCs and RRs must demonstrate an adequate understanding of these risks, while IFMs must apply asset‑level ML/TF risk scoring and due diligence, taking account of the ML/TF vertical risk assessment for VASPs and FATF guidelines. Luxembourg depositaries may act for funds investing directly in crypto‑assets but must establish adequate operational models and notify the CSSF beforehand; custody arrangements may trigger MiCAR authorisation or notification requirements depending on the services offered.