The Luxembourg financial regulator, the Commission de Surveillance du Secteur Financier (CSSF), has announced a significant shift in the administrative process governing the submission and identification of fund prospectuses. In April 2025, the VISA stamping system has been replaced by a new digital e-Identification procedure. This change applies to prospectuses of UCITS, Part II UCIs, SICARs, and SIFs.
Under the revised framework, each new or amended prospectus
submitted to the CSSF receives a unique identification number and
an associated e-Identification date. Both elements are clearly
displayed on the first page of the prospectus.
Submissions have been transitioned to a newly developed
e-Identification module within the CSSF's eDesk platform. This
digital interface is intended to streamline the handling of
prospectus filings and support a more efficient, automated
process.
Alongside the introduction of this tool, the CSSF implemented a revised administrative approach that distinguishes between changes that require regulatory approval and those that do not. A new list of amendments considered minor—and therefore not subject to prior review—has been established. Such changes may be integrated into the prospectus without the need for prior authorisation from the CSSF. However, the regulator retains the right to request documentation at a later stage as part of its ongoing supervisory responsibilities.
A comprehensive guide has been published via eDesk including the categories of changes exempt from prior review, applicable conditions, procedural instructions, and a FAQ section.
The changes exempting from prior review from the CSSF include inter alia changes in share classes, amendment to the initiator, non-material changes to an existing sub-fund or to the general part of the prospectus, non-material ESMA or other related updates to ensure compliance with FAQs, guidelines and recommendations.
As stated in FAQ document, the amendments can been notified to the CSSF at the same time the updated prospectus is submitted for e-identification on Edesk.
However, should any modification within the prospectus impact the articles of association or the management regulations of the UCI, the file must be submitted for review to the CSSF.
The current procedures for prospectus changes requiring prior review or express authorisation remain unchanged and continue to apply in accordance with existing legal and regulatory frameworks.
This upcoming reform is expected to modernise regulatory
processes, reduce administrative burdens, and enhance overall
efficiency for market participants, while preserving the core
principles of regulatory oversight and investor protection.
Should you require further information or assistance, our
Investment Funds team would be pleased to support you.
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.
