October 2025 was a day of transition in Luxembourg:
While His Royal Highness Grand Duke Guillaume formally succeeded
his father, Grand Duke Henri, marking a historic moment for the
country, the Luxembourg government also deposited Draft Bill No.
8628 (“AIFMD II Draft Law”) to implement AIFMD II into Luxembourg law, marking a
milestone for Luxembourg's investment funds
industry.
Background
AIFMD II, adopted in March 2024, is the EU's response to
evolving market practices and supervisory experience since the
original AIFMD's entry into force in 2011. Rather than
overhauling the existing framework, AIFMD II aims to address
identified gaps, enhance supervisory convergence, and further
harmonize rules across Member States. Notably, AIFMD II introduced
targeted reforms in areas such as loan origination by funds,
liquidity management for open-ended funds, delegation arrangements,
and depositary functions.