On 27 June 2025, the CSSF published Circular 25/894, which repeals CSSF Circular
15/612. Circular 15/612 is well-known to alternative managers as it
was used by Luxembourg AIFMs on a daily basis to register new AIFs
that they manage with the CSSF. The new Circular had been announced
by the CSSF and was expected by the industry.
Although the approach taken by the new Circular remains
generally consistent with the prior Circular for Luxembourg
authorised AIFMs, according to the CSSF's publication on the same date, the
scope of the new Circular is however broader, as it applies to all
investment funds not authorised by the CSSF (including European
UCITS) that are managed by a Luxembourg IFM.
