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ARTICLE · 09 OCTOBER 2025

Luxembourg On Track For AIFMD II Transposition

ELVINGER HOSS PRUSSEN, société anonyme
Explore more from ELVINGER HOSS PRUSSEN, société anonyme

The process of transposing AIFMD II has kicked off in Luxembourg. Draft Bill No 8628, which amends the UCI Law and the AIFM Law ("Bill") was tabled in Parliament on 3 October 2025.

LuxembourgFinance and Banking
Frédérique Lifrange
Frédérique Lifrange
Virginie Lebbe
Virginie Lebbe

The process of transposing AIFMD II1 has kicked off in Luxembourg. Draft Bill No 8628, which amends the UCI Law2 and the AIFM Law3 ("Bill") was tabled in Parliament on 3 October 2025.

The Bill implements the various provisions of AIFMD II on a one-to-one basis, without any gold plating and includes the following options given to Member States:

  • List of permitted services: The list of authorised services has been extended to includecredit servicing (relevant for AIFMs), benchmark administration (relevant for AIFMs and UCITS management companies ("UCITS ManCos")). It is also specified that AIFMs and UCITS ManCos will be authorised to perform, as an ancillary service for third parties, the same functions and activities that they already perform in relation to the funds they manage, if they have an adequate framework for managing conflicts of interest. For this last point, the preparatory work specifies the broad interpretation to be given to both (i) the

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