Luxembourg has moved swiftly to publish the bill of law
implementing AIFMD 2 and UCITS 6 into national law.
On 3 October 2025, bill of law no 8628 implementing Directive
(EU) 2024/927 on delegation arrangements, liquidity risk
management, supervisory reporting, the provision of depositary and
custody services and loan origination by alternative investment
funds, commonly known as “AIFMD 2”, was submitted to
the Luxembourg Parliament.
Key developments
The amendments will impact both the law of 2010 on UCIs (UCI
Law) and the law of 2013 on AIFMs (AIFM Law). Most of the
provisions in AIFMD 2 are being implemented “as is”
into the UCI Law and the AIFM Law.
However, Luxembourg is taking the opportunity to introduce some
additional flexibilities into these laws and has also provided
important clarifications in the “commentary”
(commentaires des articles), particularly regarding
substance requirements, ancillary activities, delegation, loans and
certain definitions
