On 19 December 2025, the CSSF published Circular 25/901, which repeals certain previous and dated CSSF circulars regarding specialised investment funds, SICAR and UCI Part II funds with the aim of modernising, clarifying and simplifying the current rules and CSSF interpretations, underlying the CSSF's objective of contributing to the appeal of Luxembourg as a centre for alternative funds in the years to come.
The CSSF Circular is accompanied by a Glossary outlining the key concepts in the non-UCITS and non-MMF domain. This document aims to facilitate technical discussions with the regulator on private assets by explaining the CSSF's interpretation of these concepts. Its purpose is not to introduce new concepts but to formalise existing practices, serving as a reference for both the industry and the CSSF regarding prevailing market standards.
It details the CSSF's expectations regarding overall fund investment strategies and addresses various asset classes (such as private equity, private debt, hedge funds, funds of funds, real estate, infrastructure, virtual assets, and other physical assets), as well as underlying strategies (primary or secondary investments, co-investment, tokenisation, and intermediary models).
Additionally, the document explains current concepts related to capital raising models (commitment vs. subscription) and redemption, with the CSSF, for the first time, clearly distinguishing between commitment-based and subscription-based approaches. Further guidance is also provided on liquidity management mechanisms.
CSSF Circular 25/901 will apply as from 19 December 2025 and will replace CSSF Circular 02/80, 07/309, 06/241 and chapters G and I of 97/75 with effect from the same date. Chapter H of 91/75 and Circular 08/356 will no longer be applicable to Part II funds. While the core principles of these circulars are preserved, they have been updated in a new document to reflect recent market developments, particularly the development and retailisation of private market funds.
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.
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.
