Regulatory Blog

On 17 July 2026, the Cyprus Securities and Exchange Commission published Circular C792 providing implementation guidance on the Active Account Requirement and the related representativeness obligation under Articles 7a and 7b of Regulation (EU) 648/2012 on OTC derivatives, central counterparties and trade repositories, as supplemented by Regulation (EU) 2026/305. The Circular is addressed to CIFs, UCITS management companies, AIFMs, and non-financial counterparties.

On 21 July 2026, the CSSF published Version 5 of its FAQ on the Sustainable Finance Disclosure Regulation. The update modifies a single question, Section II, Question 1, but carries practical implications for how Luxembourg fund managers assess and process changes to Article 8/9 SFDR precontractual templates.

The Jersey Financial Services Commission published a revised Alternative Investment Funds Code of Practice, marking the culmination of a consultation process that began in October 2025. The central change is that Jersey's single AIF Code has been divided into two separate instruments: an EU/EEA-focussed code, effective from 16 April 2026, and the existing AIF Code, which now applies solely to the UK regime.

On 6 May 2026, the Cyprus Securities and Exchange Commission issued Circular C776, confirming its adoption of the ESMA Guidelines on Liquidity Management Tools of UCITS and open-ended AIFs. The Guidelines, published by ESMA on 12 March 2026, are directed at UCITS management companies (including self-managed UCITS) and alternative investment fund managers (including internally managed AIFs).

On 22 April 2026, the CSSF announced updated procedures for cross-border management notifications and de-notifications for Luxembourg-domiciled Investment Fund Managers operating under a European passport. These changes, effective from 22 April 2026, aim to enhance efficiency and transparency in the notification process using digital platforms.

On 10 April 2026, the CSSF issued a communication to the investment fund industry regarding the activation of the "Liquidity Management Tool" module. This follows the implementation of additional liquidity management requirements introduced by the Law of 3 March 2026, which transposes Directive (EU) 2024/927.

On 13 March 2026, the Cyprus Securities and Exchange Commission issued Circular 759, to inform relevant entities about the adoption of the European Securities and Markets Authority’s guidelines on outsourcing to cloud service providers. This replaces Circular 457 from July 2021.

The Cyprus Securities and Exchange Commission recently issued Circular E743, introducing significant updates to liquidity management requirements for Alternative Investment Funds and Undertakings for Collective Investment in Transferable Securities.

Effective 16 April 2026, Luxembourg introduces enhanced liquidity management obligations for UCITS and open-ended AIFs under the Law of 3 March 2026, aligning with EU Directive 2024/927.

On 27 February 2026, published in the Official Journal of the European Union, regulatory technical standards introducing harmonised rules for liquidity management tools applicable to Alternative Investment Fund Managers and Undertakings for Collective Investment in Transferable Securities across the EU.

The Luxembourg Special Limited Partnership has become the go-to vehicle for private equity, venture capital, and real estate funds. It offers flexibility, tax efficiency, and minimal regulatory hassle, but only if you structure it correctly. Get it wrong, and you could face serious regulatory consequences.

The European Securities and Markets Authority, in October 2025, published its final draft Regulatory Technical Standards for open-ended loan-originating Alternative Investment Funds under the AIFMD. These standards focused on liquidity management, stress testing and redemption policies for open-ended AIFs.