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