The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) has made available in the Collective Investment Sector Reporting Tool (CISERO) on the CSSF eDesk platform the Self-Assessment Questionnaire, Separate Report and Management Letter for UCIs with financial year-ends of 31 January 2025, 28 February 2025 and 31 March 2025, incorporating limited updates driven mainly by the entry into force of Circular CSSF 24/856 and supervisory feedback. It also implemented a new CISERO Dashboard section to support submission of the letter required when a statutory auditor issues a modified audit opinion. Key changes linked to Circular CSSF 24/856 include updates to the SAQ to add a question on correct classification of passive instances of non-compliance with UCI investment rules and to remove the question on the number of active instances of non-compliance, in the context of new notification forms. The SAQ “NAV determination” section was expanded to reflect the circular’s scope covering other errors, including whether a formalised policy exists to address such errors and two questions on organisational arrangements for compensating investors subscribing through financial intermediaries. In the Separate Report, a new procedure requires the statutory auditor to review, on a limited sample, the classification of passive non-compliance (two instances for UCITS/UCIs and one for SIFs/SICARs); reviews of active non-compliance and significant NAV calculation errors shifted from full-population testing to risk-based sample reviews, with sample sizes set at three, two and one items respectively for active non-compliance (UCITS, UCIs Part II, and SIFs/SICARs) and two and one items respectively for significant NAV errors (UCITS/UCIs Part II, and SIFs/SICARs). Procedures relating to reviewing the existence and sampled application of a formalised policy for non-compliance and significant NAV errors were removed, and various questions were clarified through wording changes and updated tooltips. For UCIs with financial year-ends after 31 March 2025, the templates will be made available three months before the relevant year-end. The new CISERO section for modified audit opinions applies to UCIs with financial year-ends from 31 December 2024 and indicates the letter must be filed within one month after publication of the annual report, with submission now required via CSSF eDesk rather than the transmission method specified in Circular CSSF 21/790, which the CSSF plans to update in a future review.
Luxembourg Commission de Surveillance du Secteur Financier 2025-02-03
Luxembourg Commission de Surveillance du Secteur Financier updates CISERO UCI reporting templates and adds eDesk submission for modified audit opinion letters
The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) has updated the Collective Investment Sector Reporting Tool (CISERO) on its eDesk platform, incorporating changes from Circular CSSF 24/856 and supervisory feedback. Updates include modifications to the Self-Assessment Questionnaire (SAQ) and Separate Report, focusing on passive non-compliance classification and NAV determination. A new CISERO Dashboard section supports the submission of letters for modified audit opinions, with changes in submission procedures for UCIs with financial year-ends from 31 December 2024.