CSSF liquidity management tool deadline approaching: Luxembourg fund managers should act now
The CSSF has now set out its expectations for the implementation in Luxembourg of the new liquidity management tools framework for Luxembourg-domiciled UCITS and Luxembourg-authorised AIFMs managing open-ended AIFs.
In its communication of 18 March 2026, the CSSF states that the new requirements apply from 16 April 2026 and introduces a dedicated eDesk process for the related filings.
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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CSSF Update – New Circular on NAV Error – CSSF Circular 24/856
The New CSSF Circular 24/856 replacing Circular 02/77 as from 1st of January 2025, introduces changes on the following main points :
– Responsability of UCI’s governing body to prevent errors/non-compliance
– Implementation of New Errors
– Obligation of the responsible person to compensate the fund for the errors occured
Understanding the key changes in AIFMD II : enhancing cross-border operations and governance
Following extensive discussions and negotiations, on 20 July 2023 the European authorities [the Council of the EU and the European Parliament] reached a political agreement on the revision of Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD), leading to the issuance of AIFMDII on 7 February 2024.
These amendments aim to harmonise existing regulatory practices, ensuring robust governance and investor protection while facilitating cross-border operations of alternative investment funds (AIFs) and their managers (AIFMs). After publication in the EU’s Official Journal on 26 March 2024, AIFM2.0 will come into force on 15 April 2024. EU member States have two years to implement the directive.
Let’s delve into the significant changes introduced by AIFMD II across various aspects of alternative investment management :
- Enhanced cross-border possibilities for depositaries
- Ancillary Services Expansion
- Enhanced AIFM Authorisation Requirements
- Regulation of AIFs with Lending Activities
- Liquidity Management Tool
LUXEMBOURG RAIF SUCCESS SEDUCES FOREIGN AUTHORITIES
The success of RAIF, which since 2016 has been helping to make Luxembourg’s fund management industry more attractive, is now being felt abroad : on January 31, 2024, SWITZERLAND launched its own reserved, unregulated fund, the Limited Qualified Investor Fund (“L-QIF”).
On January 31, the Federal Council issued a decree implementing the Swiss Collective Investment Schemes Act (“CISA”, June 23, 2006), which establishes a new category of investment funds reserved for professional investors, like Luxembourg’s FIAR: the LQIF will offer sophisticated investors and fund managers even greater choice in structuring their investments.
Its main features are :
– no supervision or approval by FINMA (Swiss Financial Market Supervisory Authority);
– no risk diversification rules.
Further information here
2023 in review
Looking back on an exceptional year…
As we say goodbye to 2023, we are glad to share some of our highlights from this remarkable year.
1) New office. We have moved into a magnificent new office space, thoughtfully designed for both comfort and professionalism. Our new spaces are now ready to host meetings and business events, creating a welcoming environment for our clients and partners.
2) Digital Revolution. In 2023 We launched our all-new website, providing a user-friendly platform to explore our services, our story and legal insights.
3) Smooth fund migration. Our team successfully completed the migration of two UCITS funds, showcasing our competence in tackling complex regulatory issues in the financial sector.
4) Extending our reach. We are proud to have welcomed new clients to the Marjac family, reinforcing our mission to provide exceptional legal services.
Thank you for your loyalty and support throughout the year. Let’s look forward to a prosperous 2024 filled with more achievements
Celebrating our 5th Birthday!
We are celebrating our 5th Birthday !
Under the banner of “The Fund Ladies”, we set out with a clear vision – to create a boutique law firm that provides a personalised service that would make every day feel like a birthday for our clients,
Over the past five years, we have evolved and transformed into “All About Funds”. This transition signified our commitment to becoming a comprehensive hub for our clients. Yet, amidst this growth, we have remained a boutique firm, dedicated to providing bespoke solutions and a client-centric approach.
Our founding principle of treating our clients as if every day is their birthday remains at the heart of our ethos. We are here to surprise you with exceptional service, swift responses and innovative solutions. Your success is our ultimate celebration.
On this special day, we extend our heartfelt gratitude to our clients, partners and everyone who has been a part of our journey. Your trust, support, and collaboration have been the cornerstones of our success. Here’s to many more years of growth, success and celebrating every day with the spirit of a birthday.
Thinking of a MIGRATION?
We have recently completed the migration of service provider for two UCITS funds, demonstrating our team’s dedication and expertise. This journey has highlighted two key factors that can make all the difference to the process.
Factor 1: Patience and a skilled coordinator:
UCITS migrations often take longer than expected. It’s like conducting an orchestra; you need an experienced “conductor” to harmonise the moving parts. This leader should understand regulatory nuances and adapt quickly to unforeseen challenges.
Factor 2: Stay engaged with service provider:
To ensure a seamless UCITS migration, maintain ongoing engagement with your service provider until an effective migration is achieved. This open channel of communication will minimise disruption and help you navigate regulatory changes smoothly.
UCITS migration can be complex, but with the right coordination and consistent engagement with service providers, success is feasible. If you are facing UCITS migration challenges or need expert guidance, contact us. Together, we can orchestrate a migration that meets your regulatory requirements and business objectives.
Who is a regulatory lawyer?
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