Multi-Compartment Structures For Unregulated Luxembourg SCSp / SCS AIFs

On 30 July 2026, Bill of Law n° 8814 (“Bill of Law”) was introduced to the Luxembourg Parliament with a view to amending the law of 12 July 2013 on alternative investment fund managers, as amended (“AIFM Law”).

If approved, alternative investment funds (“AIFs”) established in the form of a common limited partnership (société en commandite simple, “SCS”) or a special limited partnership (société en commandite spéciale, “SCSp”) and, in each case, managed by an EU-authorised alternative investment fund manager (“AIFM”) would, for the first time, be permitted to adopt a multi-compartment (i.e. umbrella) structure without being subject to one of Luxembourg’s product regimes.

Background

At present, the ability to create umbrella funds comprising one or more compartments is reserved to investment funds established under one of Luxembourg’s product regimes, i.e. the law of 17 December 2010 relating to undertakings for collective investment, as amended, the law of 13 February 2007 relating