CSSF liquidity management tool deadline approaching: Luxembourg fund managers should act now

The “LMT selection” module opens on 23 March 2026, and the CSSF indicates that the relevant information must be submitted by 16 April 2026.

In practical terms, firms should now ensure that, for each in-scope fund, the relevant liquidity management tools have been selected, reflected in the constitutional and disclosure documentation, and supported by detailed internal policies and procedures governing activation and deactivation. The CSSF also makes clear that the selection must be made in light of the investment strategy, liquidity profile and redemption policy of the relevant fund.

The CSSF further states that in-scope entities must select at least two liquidity management tools from the statutory list and that the selection cannot consist only of swing pricing and dual pricing. For money market funds, it confirms that only one tool may be selected by way of derogation.

A separate legal point remains on the reporting timetable. While the substantive framework should be implemented on the basis of the 16 April 2026 application date, the statutory entry into force of certain supervisory reporting provisions appears to have been deferred until 16 April 2027. Firms should therefore be ready to follow the CSSF’s operational timetable, while keeping under review the legal basis for mandatory reporting already in April 2026.

For managers of Luxembourg funds, this is now an active implementation workstream. The immediate priority is to complete the fund-by-fund LMT analysis, update documentation, finalise internal procedures and prepare for the CSSF eDesk filing before 16 April 2026.

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