Regulatory update :
Luxembourg
AIFMD II changes to management notification and de-notification procedures for the European passport
The Law of 3 March 2026 transposed AIFMD II into Luxembourg law, introducing additional activities, functions and/or services for UCITS management companies and authorised alternative investment fund managers.
In this context, the CSSF has published updated templates of notification letters for cross-border management and marketing activities within the European Economic Area (EEA), available on the AIFM European passport and UCITS ManCo European passport pages of its website. The updated templates had to be used as from 31 July 2026. The dedicated eDesk module for cross-border management notifications and de-notifications (or the equivalent CSSF API/S3 solution) was updated on the same date, with further guidance available in the updated IFM guidelines on cross-border management notification and de-notification procedures.
The CSSF has reminded supervised entities that, to pursue these new activities, functions or services in another Member State, an IFM must first be authorised by the CSSF to provide them in Luxembourg.
ESMA/CSSF Common Supervisory Action on the risk management function of UCITS management companies and AIFMs
On 3 July 2026, ESMA launched a CSA with NCAs on the risk management function of UCITS management companies and authorised alternative investment fund managers across the EU, using a common methodology developed with NCAs to ensure supervisory convergence.
The CSA aims to assess the extent to which IFMs have established an effective and independent risk management function with adequate staffing, authority, knowledge and expertise, ensuring that material risks, including market, credit, liquidity, counterparty, sustainability and operational risks, are properly identified, measured, monitored and managed.
On 27 July 2026, the CSSF launched the CSA in Luxembourg by requesting a sample of Luxembourg-based IFMs to complete a questionnaire focused on (i) the governance and organisation of the risk management function, (ii) the identification, measurement and monitoring of risks, and (iii) reporting to senior management and governing bodies. These IFMs were contacted directly by the CSSF by email, and the CSSF has reminded IFMs to keep the email addresses and roles of their eDesk users up to date. Responses will need to be submitted through the CSSF's eDesk Portal once the relevant section becomes available.
ESMA/CSSF registers of authorised ELTIFs
ESMA maintains and periodically updates its register of ELTIFs, providing a consolidated overview of ELTIFs authorised across the EU. Fund managers and sponsors considering the ELTIF wrapper should continue to monitor the register alongside the regulatory technical standards under the revised ELTIF Regulation covering redemption policy, matching mechanism and cost disclosure, which were finalised in Commission Delegated Regulation (EU) 2024/2759, published in the Official Journal of the EU on 25 October 2024 and in force since 26 October 2024. The CSSF also publishes a list of fund units subject to the ELTIF Regulation as amended by Regulation (EU) 2023/606, updated on 1 September 2026.
CSSF guidelines on cross‑border management notification and denotification procedures
On 22 April 2026, the CSSF published guidelines setting out its approach to cross-border management notifications and denotifications for management companies and AIFMs operating under the UCITS and AIFMD European passports. The guidelines aim to clarify the procedural steps to be followed when initiating or terminating cross-border management activities, as well as the information to be provided to the CSSF and the relevant host authorities.
These guidelines are particularly relevant for Luxembourg-domiciled management companies and AIFMs with cross-border operations, as they contribute to greater consistency and transparency in passporting processes. In practice, firms may need to review their internal processes for regulatory notifications to ensure alignment with the clarified expectations and timelines set out by the CSSF.
CSSF communication on the requirement to notify the suspension of redemptions in the LMT activation module
On 18 September 2026, the CSSF published a communication extending the scope of the eDesk “LMT activation” module to include notifications of the activation and deactivation of suspensions of redemptions (only) under the national law provisions applicable to Luxembourg-domiciled UCIs subject to Part II of the 2010 Law, SIFs governed by the 2007 Law, and SICARs governed by the 2004 Law. Although a suspension of redemptions only (without suspension of subscriptions) does not qualify as an LMT under the 2026 Law transposing AIFMD II, it has been integrated into the LMT activation module to simplify notification procedures for market participants. The notification obligation through the eDesk LMT activation module has applied since 21 September 2026; however, the administrative requirements, including the submission of supporting documentation, remain unchanged and must continue to be submitted through the usual communication channels. The CSSF has also reminded fund structures that are not managed by a Luxembourg-domiciled authorised AIFM that they must notify the CSSF of suspensions of subscriptions, repurchases and redemptions, as well as the creation of side pockets previously approved by the CSSF, through the same module. In addition, the CSSF reiterated the requirements under the 2026 Law for existing sub-funds (as from 16 April 2026) and new sub-funds (as from their date of establishment) to select, activate and deactivate LMTs through the eDesk procedure.