On 27 June 2025, the CSSF published Circular 25/894, which repeals CSSF Circular 15/612. Circular 15/612 is well-known to alternative managers as it was used by Luxembourg AIFMs on a daily basis to register new AIFs that they manage with the CSSF. The new Circular had been announced by the CSSF and was expected by the industry.
Although the approach taken by the new Circular remains generally consistent with the prior Circular for Luxembourg authorised AIFMs, according to the CSSF's publication on the same date, the scope of the new Circular is however broader, as it applies to all investment funds not authorised by the CSSF (including European UCITS) that are managed by a Luxembourg IFM.
These IFMs (including registered AIFMs, authorised AIFMs and UCITS management companies) must notify the CSSF of their management of investment funds via the dedicated eDesk procedure.
In addition, the CSSF now requires Luxembourg IFMs to inform it of the following AIF's service providers, in addition to those already requested in the previous form:
- UCI administrator(s);
- portfolio management delegate(s) and sub-delegate(s).
The CSSF has also published a Q&A which is available here.
Circular CSSF 25/894 came into force on 27 June 2025.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
