Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 23 OCTOBER 2026

Luxembourg Financial Services Regulator CSSF Issues First FAQ On Fund Tokenisation

K&L Gates
K&L Gates
Contributor
K&L Gates

K&L Gates

The Firm K&L Gates is an integrated, international law firm. As a single global law firm, truly...

View firm profile
Explore more from K&L Gates

Luxembourg's financial regulator CSSF has published its first FAQ on tokenisation of investment funds, addressing how traditional asset classes can be issued in tokenised form on distributed ledger technology. The guidance clarifies regulatory requirements for UCIs, administrators, and control agents while maintaining a technologically neutral approach that evaluates risks based on how the technology is used rather than the technology itself.

LuxembourgFinance and Banking
Jan Boeing Dr.
Jan Boeing Dr.
Maria Savvidou
Maria Savvidou

On 2 October 2026, Luxembourg’s financial regulator, the Commission de Surveillance du Secteur Financier (CSSF), published the first version of its FAQ on tokenisation (FAQ), addressing the tokenisation of investment funds: the digital representation of assets on distributed ledgers, or the issuance of traditional asset classes in tokenised form so they can be issued, stored and transferred on a distributed ledger technology (DLT).

It is to be noted that the FAQ are not meant to be a complete guide to tokenisation under Luxembourg law, but rather a listing of recurrent questions received by the CSSF, with no vocation to treat the topic exhaustively. The FAQ are without prejudice to other legal obligations, including AML requirements, and will be updated and adapted as necessary; entities should regularly check the CSSF’s website for updates.

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

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

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

Luxembourg Introduces Multi-compartment Structures For Unregulated AIF Limited Partnerships

Luxembourg has introduced a landmark legislative reform allowing unregulated alternative investment fund (AIF) limited partnerships to adopt multi-compartment structures. This development enables fund sponsors to consolidate multiple investment strategies, investor classes, and fund-level structures within a single limited partnership, significantly reducing complexity and administrative burden while maintaining creditor protection and investor segregation.
LuxembourgFinance and Banking
Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
Article

Spotlight On Luxembourg

CMS Luxembourg's M&A experts analyze the Grand Duchy's evolving dealmaking landscape, examining how regulatory complexity and fund services consolidation are reshaping Luxembourg's dual role as both a domestic market and Europe's premier cross-border structuring hub. The discussion reveals why private equity houses are driving unprecedented consolidation among fund service providers in the world's second-largest investment fund center.
LuxembourgFinance and Banking
CMS Luxembourg
CMS Luxembourg
Article

Text-Message Marketing In Texas, One Year After SB 140

Texas Senate Bill 140 (SB 140) took effect 1 September 2025, and applies to conduct occurring on or after that date. The bill amended Section 302 of the Texas Business and Commerce Code to extend registration and disclosure requirements to text messages by expanding the definition of “Telephone solicitation,” which previously applied only to a “telephone call,” to include certain transmissions of text or graphic messages and images. In addition, SB 140 added a definition of “Telephone call” that incorporates the definition found in Section 304, which includes certain text or graphic messages and images, but excludes certain agreed-to transmissions.
United StatesMedia, Telecoms, IT, Entertainment
K&L Gates
K&L Gates
Article

SEC And CFTC Open Door To Tokenized Markets After Clarity Fails To Advance

The SEC and CFTC have issued coordinated regulatory relief measures that significantly advance crypto-based trading infrastructure in US markets, bypassing Congressional gridlock on the CLARITY Act. These orders establish new frameworks for tokenized securities venues and passive software providers, potentially reshaping how digital assets are traded and accessed in regulated markets.
United StatesFinance and Banking
K&L Gates
K&L Gates
Article

EU AI Act: Final Guidelines On Transparency Obligations Under Article 50

The European Commission has issued guidelines on transparency obligations under Article 50 of the EU AI Act, clarifying how providers and deployers must inform individuals when they interact with AI systems or are exposed to AI-generated content. These non-binding guidelines address a wide range of AI applications, from chatbots to deepfake technologies, and establish four main transparency scenarios with specific disclosure requirements that businesses must now prepare to implement.
European UnionGovernment, Public Sector
K&L Gates
K&L Gates
Article

Venezuela's Reopening: Investment, Infrastructure, And Technology Opportunities In A Rebuilding Latin America

Venezuela's post-Maduro reopening is creating unprecedented opportunities for foreign investors across energy, mining, telecommunications, and infrastructure sectors. With expanding OFAC sanctions relief, landmark legislative reforms, and major US companies nearing multibillion-dollar deals, the country presents investment prospects not seen in a generation—though success requires disciplined navigation of corruption, security, and regulatory risks.
United StatesInternational Law
K&L Gates
K&L Gates
Article

New EU Withdrawal Button Requirement: Practical Implications And Recommendations For US And Global Online Sellers

The European Union's new Consumer Rights Directive amendment introduces a mandatory "withdrawal button" for online merchants, fundamentally changing how consumers exercise their 14-day right of withdrawal from distance contracts. This requirement, effective June 19, 2026, applies to any trader—including US-based companies—actively selling to EU consumers, creating new compliance obligations around button placement, design standards, data collection, and confirmation processes. Understanding whic
European UnionConsumer Protection
K&L Gates
K&L Gates
Article

United States Opens A New Chapter In Civil Nuclear Cooperation With The Kingdom Of Saudi Arabia

The United States and Saudi Arabia have signed a landmark nuclear cooperation agreement under Section 123 of the Atomic Energy Act, establishing the legal framework for decades of civilian nuclear partnership. This agreement resolves years of debate over nonproliferation conditions and positions US companies to participate in Saudi Arabia's ambitious civil nuclear program. The deal carries significant implications for US engagement in the Middle East, international nuclear commerce, and the global competiti
GlobalGovernment, Public Sector
K&L Gates
K&L Gates
Article

China’s A-Share Market Expands Closing-Price Trading: Implications For Funds And Institutional Investors

China's stock exchanges have implemented three major trading rule changes effective July 6, 2026, designed to enhance market quality and align practices with international standards. The reforms expand after-hours trading, modify public fund pricing mechanisms, and adjust price limits for risk-warning stocks. How will these structural changes impact institutional investors, ETF efficiency, and overall market participation in China's evolving capital markets?
ChinaFinance and Banking
K&L Gates
K&L Gates