On March 6, 2025, the CSSF published a communiqué on a new "e-Identification" system, which will replace the current VISA procedure for the prospectuses of UCITS, Part II UCIs, SICARs, and SIFs, in April 2025.
This new system aims to modernise administrative procedures, enhance efficiency while ensuring robust investor protection standards. The CSSF also seizes this opportunity to introduce a list of amendments to the prospectus, which do not legally require authorisation and prior review by the CSSF. A new guide will be made available on eDesk not only including (i) the details of the procedure, (ii) the list of amendments covered, (iii) the applicable conditions and (iv) a FAQ section, but also a technical part to facilitate the IT and operational implementation. This guide will be published on March 20, 2025.
New e-Identification System
The new e-Identification includes a unique Identification number (formatted as YYYY/NNNNNN-NNNNNN-N- PC) and e-Identification date, that will be assigned to each prospectus. These will be displayed on the first page of the prospectus. The submission for identification of any new or revised fund prospectus will be conducted through the dedicated eDesk "e-Identification prospectus application".
Changes in the CSSF administrative procedure
Amendments with no CSSF approval
An exhaustive list of amendments to the prospectus that do not require authorization and prior review by the CSSF will be set out in the guide. However, the CSSF reserves the right to conduct an ex-post analysis, based on a risk-based approach. The CSSF underlines that the fund's governing body is responsible to ensure compliance with regulatory requirements.
Amendments subject to CSSF approval
The current administrative procedure for requests and amendments to prospectus that require the CSSF's prior review (i.e., not covered by the list of amendments mentioned above) will continue to apply.
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.
