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ARTICLE · 17 APRIL 2026

EU Sponsors - A Cost‑efficient Luxembourg Fund Entry Point Using A Registered Manager

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Luxembourg offers a cost-efficient alternative for emerging fund managers through its registered AIFM structure, commonly known as the "small manager" route. This approach allows fund managers to establish Luxembourg AIFs while avoiding the substantial costs associated with authorised host AIFMs, though it comes with specific asset thresholds and marketing limitations.

LuxembourgFinance and Banking

When planning for new alternative investment fund (AIF) structures, EU fund sponsors (EUFS) often realise that a Luxembourg AIF is best to target foreign investors. At the same time, EUFS are aware that Luxembourg fund structures often involve higher costs than domestic alternatives.

A Luxembourg AIF must appoint a fund manager. For EUFS, it can either be their in-house authorised alternative investment fund manager (Authorised AIFM) if the EUFS avail of one, or an authorised “host” AIFM in Luxembourg (Host AIFM). Host AIFMs come with a price tag, which explains partially the increased costs of Luxembourg fund structures.

However, for EUFS that wish to avoid the costs of a Host AIFM, the set-up with a Luxembourg registered AIFM could be a viable solution. The registered AIFM route is however only open to EUFS managing unleveraged closed-ended AIFs provided the asset under management in such AIFs are, on a group wide basis, below EUR 500 million. In case of leverage or open-ended

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