Luxembourg: Finance and Banking

The transitional period under MiCAR for virtual asset service providers has ended, creating significant regulatory obligations for crypto-asset service providers and their customers. Luxembourg's CSSF has issued guidance on the implications for VASPs operating without proper authorization, third-country providers targeting EU clients, and the strict interpretation of reverse solicitation exemptions.

In March 2026, we published a client alert1 examining the Commission de Surveillance du Secteur Financier’s (CSSF) updated FAQ on crypto assets in investment funds and the key changes since the initial 2022 guidance.

European institutional investors increasingly favor Article 8 funds under SFDR, which promote environmental and social characteristics alongside good governance practices. US fund managers face strategic decisions when entering the EU market, weighing the benefits of Article 8 classification against operational constraints and investor preferences. The regulatory landscape offers flexibility in ESG implementation, though upcoming SFDR 2.0 reforms will reshape these disclosure requirements by late 2027.