The Luxembourg Commission de Surveillance du Secteur Financier has overhauled its circular-based framework for specialised investment funds (SIFs), investment companies in risk capital (SICARs) and Part II undertakings for collective investment (Part II UCIs) through a consolidated circular intended to align supervisory expectations with current market practices. The new circular replaces several legacy texts while retaining their core principles, and it updates key limits and disclosures to reflect practical experience. Circular CSSF 25/901 repeals Circulars CSSF 02/80, CSSF 07/309, CSSF 06/241 and Chapters G and I of Circular IML 91/75, and it removes the applicability of Circular CSSF 08/356 and Chapter H of Circular IML 91/75 for Part II UCIs. Existing rules adopted by funds or compartments authorised by the CSSF before the circular’s entry into force are not called into question. The circular raises current investment and borrowing limits and applies a more flexible approach linking incurred risks to investor profile, allows derogations based on a duly motivated justification, clarifies the use of indirect investments, and sets out expectations for elements to be included in fund sales documents. Alongside the circular, the CSSF published a separate technical compilation of key concepts and terms used for investment funds other than UCITS and money market funds (MMFs), explaining how the CSSF understands common alternative investment fund concepts in context. The compilation is expressly non-exhaustive and was not formalised as a CSSF circular or regulation to preserve flexibility, and its first version covers investment policy, strategies and asset classes, investment methods, and subscription and redemption models.
Luxembourg Commission de Surveillance du Secteur Financier 2025-12-19
Luxembourg Commission de Surveillance du Secteur Financier issues a new circular for SIFs, SICARs and Part II UCIs and publishes a key concepts compilation
The Luxembourg Commission de Surveillance du Secteur Financier has revamped its framework for specialised investment funds, investment companies in risk capital, and Part II undertakings for collective investment to align supervisory expectations with market practices. Circular CSSF 25/901 consolidates and updates key limits and disclosures, allowing more flexibility in risk management and fund documentation. Additionally, the CSSF released a non-exhaustive technical compilation of key concepts for alternative investment funds to enhance understanding without formal regulatory status.