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Regulatory Blog

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CSSF updates crypto-asset guidelines: Key changes for investment funds
On 4 February 2025, the Luxembourg’s Commission de Surveillance du Secteur Financier (CSSF) updated its FAQs on crypto-assets, reflecting significant regulatory changes and providing guidance for various stakeholders. Here's a concise summary:
ESMA guidance on MiCA transitional periods: What CASPs and investors need to know
The European Securities and Markets Authority recently issued guidance regarding the transitional periods under the Markets in Crypto-Assets Regulation. These transitional measures allow crypto-asset service providers operating before 30 December 2024, to align with MiCA requirements. However, Member States may choose to limit or forgo these transitional periods to enhance financial stability and investor protection.
CSSF Circular 25/900: Updates to the annual reporting by UCI administrators
On 16 December 2025, Luxembourg’s Commission de Surveillance du Secteur Financier published Circular 25/900, amending Circular CSSF 22/811 concerning the authorisation and organisation of entities acting as UCI administrators.
Key highlights of CSSF Circular 25/901 for Luxembourg’s investment funds
On 19 December 2025, Luxembourg’s Commission de Surveillance du Secteur Financier published Circular 25/901, which became effective the same day. This circular, streamlines and modernises the regulatory framework for Luxembourg's investment funds. By consolidating previous circulars and aligning provisions with practical experience, it establishes a unified and coherent set of rules for Specialised Investment Funds, Investment Companies in Risk Capital, and Part II Undertakings for Collective Investment.
CSSF announces 2025 AML/CFT questionnaire and upcoming AMLA preparation
On 1 December 2025, the Commission de Surveillance du Secteur Financier announced the launch of its 2025 Annual AML/CFT Questionnaire on 23 February 2026. This initiative aims to gather standardised information on money laundering and terrorism financing risks faced by entities under CSSF supervision, as well as the measures implemented to mitigate these risks.
Luxembourg tax authorities provide guidance on CIV exemption under ATAD2
On 12 August 2025, the Luxembourg tax authorities published a circular offering guidance on the Collective Investment Vehicle exemption under the reverse hybrid rules introduced by ATAD2.
CSSF’s Circular 25/894: Reporting obligations for Luxembourg fund managers
On 27 June 2025, Luxembourg's Commission de Surveillance du Secteur Financier published Circular 25/894, which establishes the obligations for Luxembourg Investment Fund Managers managing investment funds not authorised by the CSSF to provide information in respect of such funds via the completion of specific forms. This circular, effective immediately, repeals Circular CSSF 15/612 and applies to management companies subject to Chapter 15 of the UCI Law, registered AIFMs and authorised AIFMs.
CSSF issues new AML/CFT FAQ on asset side due diligence obligations
On 13 December 2024, Luxembourg's Commission de Surveillance du Secteur Financier released a new FAQ addressing Anti-Money Laundering and Countering the Financing of Terrorism on the asset side due diligence requirements under CSSF Regulation No. 12-02.
Key guidelines of CSSF Circular 24/856 on Investor Protection (NAV errors/breach of investment restrictions and other errors)
As a reminder, on 28 March 2024, Luxembourg’s Commission de Surveillance du Secteur Financier issued Circular 24/856 providing comprehensive guidelines for the protection of investors in cases of errors related to the Net Asset Value calculation, non-compliance with investment rules and other administrative errors at the level of Undertakings for Collective Investment under the supervision of CSSF. An English version of the circular has recently been released.
A comprehensive overview of the Luxembourg Non Performing Loans Law: A new legal framework
On 12 July 2024, the Luxembourg Parliament adopted the draft bill 8185, aimed at transposing Directive (EU) 2021/2167 on credit managers and credit purchasers.
CSSF issues new guidelines for investor protection in collective investment undertakings
On 29 March 2024, Luxembourg’s Commission de Surveillance du Secteur Financier issued Circular CSSF 24/856, replacing Circular CSSF 02/77.
EU reaches provisional agreement on AIFMD II and UCITS “plain-vanilla EU investment funds”
On 20 July 2023, negotiators from the European Council and the European Parliament reached a provisional agreement on new regulations aimed at improving European capital markets and strengthening investor protection in the EU. The agreement focuses on revising the Alternative Investment Fund Managers Directive (AIFMD), broadly referred to as AIFMD II, which governs managers of various investment funds including hedge funds, private equity funds, and real estate funds in the EU. Additionally, it modernises the framework for “plain-vanilla” EU-harmonised retail investment funds known as undertakings for collective investment in transferable securities (UCITS).
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