The Commission de Surveillance du Secteur Financier (CSSF) has introduced new guidelines for investment fund managers (IFMs) in Luxembourg overseeing non-CSSF-authorised funds via the Circular 25/894. This new Circular, published on 27 June 2025, repeals Circular CSSF 15/612 and aims to improve regulatory oversight and ensure the CSSF has current information on such funds managed by Luxembourg IFMs, ensuring it stays compliant with European regulatory standards.  

What are the key changes, expanded scope and new reporting obligations?

As mandated by Circular 25/894, all Luxembourg-based IFMs, including Chapter 15 management companies (ManCo15), registered AIFMs and authorised AIFMs, must notify the CSSF when managing any non-authorised investment funds. This includes European UCITS not domiciled in Luxembourg, European AIFs (whether authorised or not), non-authorised Luxembourg AIFs and third-country AIFs.  

The notification must be submitted electronically through the dedicated CSSF’s eDesk platform and provide more detailed information for each notified fund and associated service providers, such as administrators, portfolio managers and any sub-delegates. The timing of the notification will depend on the type of IFM. ManCo15s and authorised AIFMs must notify the CSSF before starting fund management, while registered AIFMs must do so no later than 10 working days after starting to manage an additional AIF. Additionally, the CSSF must be notified immediately of any significant changes to the previously submitted information or documents. The CSSF must also be notified within ten working days if an IFM ceases to manage a non-authorised fund or if the fund is liquidated.  

These expanded obligations aim to strengthen the CSSF’s supervisory framework, ensuring it has a complete and current view of all funds under the management of Luxembourg IFMs. With this improved oversight, the CSSF is better equipped to carry out its supervisory responsibilities and complete its reporting requirements to the European Securities and Markets Authority (ESMA).  

This update serves as a reminder to IFMs to review their compliance protocols and make sure that reports are correct and submitted on time, as noncompliance may lead to regulatory scrutiny along with potential penalties.  

In this era of evolving regulations, maintaining robust internal controls and engaging proactively will be essential for successfully navigating the changing landscape. To adapt with confidence and ensure compliance, please feel free to contact our Bolder representatives for more information about these developments and learn how our services and solutions can help you.  

Bolder Group does not provide financial, tax or legal advice and the information contained herein is meant for general information purposes only. We strongly recommend that before acting on any of the information contained herein, readers should consult with their professional advisers. The Bolder Group accepts no liability for any errors or omissions in the information, or the consequences resulting from any action taken by a reader based on the information provided herein.

Bolder Group refers to the global network of independent subsidiaries of Bolder Group Holding BV. Bolder Group Holding BV provides no client services. Such services are provided solely by the independent companies within the Bolder Group which are each legally distinct and separate entities and have no authority (actual, apparent, implied or otherwise) to obligate or bind Bolder Group Holding BV in any manner whatsoever. The operations of the Bolder Group are conducted independently and have no affiliation with third party financial, tax or legal advisory firms or corporations.