Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 12 JANUARY 2026

CSSF Streamlines SIFs, SICARs And Part II UCIs Regulations – With An Indirect Impact On RAIFs

Dechert
Dechert
Contributor
Dechert

Dechert

Dechert helps business leaders lead For more than 150 years, we’ve advised the innovators who move...

View firm profile
Explore more from Dechert

The Luxembourg supervisory authority, the CSSF, released circular 25/901 relating to SIFs, SICARs and Part II UCIs (the "Circular") on 19 December 2025...

LuxembourgFinance and Banking
Arne Bolch
Arne Bolch
Patrick Goebel
Patrick Goebel
Philippa List
Philippa List
Christine Renner
Christine Renner

The Luxembourg supervisory authority, the CSSF,1 released circular 25/901 relating to SIFs,2 SICARs3 and Part II UCIs4 (the "Circular")5 on 19 December 2025, together with a compilation on key concepts and terms used for certain private funds (the "Compilation").6 The Circular aims to modernize, clarify, simplify and consolidate the regulatory practice of the CSSF for SIFs, SICARs and Part II UCIs and provides a single and consistent set of rules that is more comprehensive and easier aligned with European regulations. Even though the Circular does not apply to RAIFs7 since they are not regulated by the CSSF, the Circular can serve as guidance for RAIFs, notably in respect of risk-spreading requirements. The Circular abolishes long-standing circulars like CSSF circular 07/309, which introduced the 30% risk spreading rule for SIFs, and CSSF circular 06/241, which defines the assessment criteria on risk capital for SICARs.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

CRD VI: The EU's Cross-border Banking Rules Are Changing For Non-EU Institutions. Are You Ready?

The EU's third-country branch regime under CRD VI fundamentally changes how non-EU banks can serve European clients, requiring most institutions to establish authorized branches or subsidiaries by January 2027. With national transposition underway and a critical grandfathering deadline already passed, affected institutions must urgently assess their EU activities, evaluate available exemptions, and determine whether their current operating models remain viable under the harmonized framework.
European UnionFinance and Banking
DLA Piper
DLA Piper
Article

CSSF Imposes Fine For AML And Sanctions Compliance Violations

Luxembourg's CSSF imposed a €56,000 fine on Stonehage Fleming Luxembourg S.A. for multiple compliance failures, including significant delays in processing sanctions screening alerts and implementing changes to screening lists. At the time of inspection, hundreds of alerts had been treated with substantial delays and 42 alerts remained completely unnoticed by the financial services provider.
LuxembourgFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

AIFMD II: Key Implementation Developments In Luxembourg

Two years on from the entry into force of Directive (EU) 2024/927, commonly referred to as AIFMD II, the 16 April 2026 transposition deadline has passed, and the state of play across the EU is best described as uneven, with compliance posture increasingly dependent on where an AIFM is authorised. However, Luxembourg, which hosts the largest shares of EU AIFs within the Union, transposed the Directive without material gold-plating.
European UnionFinance and Banking
Maples Group
Maples Group
Article

The AIFMD II Directive And Financing Transactions

The Luxembourg law of March 3, 2026 transposed the AIFMD II Directive into national law, introducing significant changes to the regulatory framework governing alternative investment funds. This article examines the practical implications for financing transactions involving Luxembourg AIFs, analyzing how the new rules on loan origination, leverage caps, concentration limits, and enhanced disclosure requirements affect both lenders and borrowers in structured finance arrangements.
LuxembourgFinance and Banking
Dechert
Dechert
Article

Reverse Solicitation: The Exception That Regulators Expect To Remain Exceptional

Reverse solicitation remains one of the most scrutinised concepts in fund distribution, offering a legitimate route for investment when approached entirely on the investor's initiative. Yet the distinction between genuine unsolicited interest and marketing activity carries significant regulatory consequences, requiring AIFMs to navigate narrow fact-specific exceptions rather than treating it as a designed distribution model.
LuxembourgFinance and Banking
Loyens & Loeff
Loyens & Loeff
Article

Luxembourg Private Funds Organised As Companies: How To Make Them Fit For Purpose

Luxembourg's partnership limited by shares (SCA) offers private fund managers a compelling corporate alternative to the special limited partnership structure, particularly for EU family offices and high-net-worth individuals. When combined with the RAIF regime, this vehicle achieves tax neutrality while maintaining the corporate governance framework that certain investors prefer. The SCA-RAIF structure addresses key legal and tax considerations while providing flexibility for secondary strategies, fund-of-f
LuxembourgFinance and Banking
Loyens & Loeff
Loyens & Loeff
Article

SEC Proposes Interval Fund Updates, Extension Of Multi-Class Relief For Closed-End Funds And BDCs

The U.S. Securities and Exchange Commission has proposed significant amendments to modernize interval fund operations and extend multiple share class eligibility to non-traded closed-end funds and business development companies. These changes would eliminate longstanding regulatory barriers by allowing interval funds to defer initial repurchase offers for up to two years, introducing monthly repurchase options, and replacing rigid liquidity requirements with principles-based approaches, while also removing
United StatesFinance and Banking
Dechert
Dechert
Article

CLO Equity Fund Market 2026 Update: Clearing Skies

The global CLO equity fund market is experiencing a cautious reopening after a period of tight arbitrage and challenging economics. With U.S. CLO issuance approaching $230 billion in the first half of 2026 and major platforms successfully raising billion-dollar funds, captive and third-party CLO equity fund structures are evolving rapidly as managers deploy sophisticated structuring technologies to provide stable execution capacity and attract institutional capital seeking diversified credit exposure with s
United StatesFinance and Banking
Dechert
Dechert
Article

Perpetual Contracts Update: CME Takes CFTC To Court

CME has filed a federal lawsuit challenging the CFTC's approval of Kalshi's bitcoin perpetual contract, raising fundamental questions about whether perpetual contracts should be regulated as futures or swaps. The case centers on allegations that the CFTC violated the Administrative Procedure Act by reversing established policy without adequate explanation, potentially reshaping the regulatory landscape for digital asset derivatives. The outcome will have significant implications for market participants, as
United StatesFinance and Banking
Dechert
Dechert
Article

CFTC Publishes Its 2026 Regulatory Priorities Agenda

The CFTC has released its 2026 regulatory priorities agenda under new Chairman Michael Selig, outlining significant proposed changes to commodity pool operator exemptions, large trader reporting requirements, and foreign exchange product classifications. Asset managers participating in commodities and derivatives markets will need to understand how these regulatory modifications may affect their registration obligations, reporting burdens, and treatment of various financial instruments.
United StatesFinance and Banking
Dechert
Dechert
Article

Concierge Medicine And Medical Aesthetics: The Private Equity Playbook For A US$590 Billion Opportunity

Private equity investment in concierge medicine, aesthetic dermatology and medispas has surged due to cash-pay economics, recurring revenue models and fragmented markets ripe for consolidation. However, navigating state-by-state corporate practice of medicine prohibitions, licensure requirements and evolving GLP-1 regulations requires sophisticated legal structuring to protect valuations and enable successful exits.
United StatesFood, Drugs, Healthcare, Life Sciences
Dechert
Dechert
Article

Preference Given: Preferred Equity's Growing Reach Across Structured Finance

Preferred equity is transforming structured finance by enabling sponsors to attract third-party capital below rated debt without diluting residual positions or triggering additional rating requirements. This analysis examines how CFOs, CLOs, NAV facilities, and other securitization vehicles are deploying bespoke preferred structures to widen investor pools while preserving manager incentives. What contractual mechanics, legal considerations, and market dynamics are driving this shift from niche accommodatio
United StatesFinance and Banking
Dechert
Dechert