LMT Activation Module Launch for Luxembourg UCITS and AIFMs

Published on 10 April 2026 Communiqué

Communication to the investment fund industry

regarding the “LMT activation” module in relation to additional liquidity management requirements for Luxembourg-domiciled UCITS, or where applicable their management company, and Luxembourg-authorised AIFMs that manage open-ended AIFs, introduced by the Law of 3 March 2026, transposing Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024

This communiqué follows up on the CSSF Communiqué published on 18 March 2026 announcing the launch of a dedicated “ Liquidity Management Tool (“LMT”) eDesk procedure”, comprising both an “LMT selection” and an “LMT activation” module. Through this procedure, Luxembourg-domiciled UCITS, or where applicable their management company, and Luxembourg-authorised AIFMs managing open-ended AIFs are required to electronically communicate to the CSSF the LMT-related information required under the Law of 17 December 2010 relating to UCIs (“2010 Law”) or the Law of 12 July 2013 on AIFMs (“2013 Law”), both as amended by the 2026 Law.

The “LMT selection” module was launched on 23 March 2026, requiring UCITS, or where applicable their management company, and authorised AIFMs to communicate their selection of LMTs to the CSSF, together with their detailed policies and procedures governing their activation and deactivation by 16 April 2026.

The CSSF hereby informs market participants that the “ LMT activation ” module has now been launched. UCITS, or where applicable their management company, and authorised AIFMs that manage open‑ended AIFs, are required to notify the CSSF as from 16 April 2026, via the “LMT activation” module, of the activation or deactivation 1 of the following:

• suspensions of subscriptions, repurchases and redemptions;
• any LMT referred to in Annex III, points 2 to 8 of the 2010 Law or Annex V, points 2 to 8 of the 2013 Law, in a manner that is not in the ordinary course of business, as envisaged in the UCITS or AIF rules or instruments of incorporation;
• side pockets, while ensuring that, in accordance with Article 15-1 of the 2013 Law and Articles 12 and 28 of 2010 Law, the CSSF is notified within a reasonable timeframe before the activation or deactivation of this LMT. The CSSF reminds market participants that the information of activation or deactivation of LMTs they provide through the eDesk procedure will subsequently be used to notify the required competent authorities, ESMA and, if applicable, the ESRB in accordance with the provisions of the 2010 Law and the 2013 Law.

In addition, Luxembourg-domiciled funds subject to Part II of the 2010 Law, specialised investment funds governed by the Law of 13 February 2007 and investment companies in risk capital governed by the Law of 15 June 2004, which do not qualify as AIFs or are not managed by a Luxembourg-domiciled authorised AIFM, shall also notify the CSSF of the activation or deactivation of suspensions of subscriptions, repurchases and redemptions, as well as the creation of side pockets previously approved by the CSSF under the “LMT activation” module, as required under the respective sectoral laws.

Market participants may refer to the CSSF Communiqué published on 18 March 2026 announcing the launch of the dedicated “Liquidity Management Tool (“LMT”) eDesk procedure”, for further details on the “LMT activation” module as well as additional information on the activation and deactivation of suspensions of subscriptions, repurchases and redemptions as well as the creation of side pockets.

1 The “LMT activation” module must only be used for notifying the CSSF of activations and deactivations of LMTs as from 16 April 2026. Deactivations of LMTs that have been activated before 16 April 2026 must not be notified through the “LMT activation” module but through the usual CSSF procedure.

Relevant for

• Investment companies in risk capital (SICARs)
• Investment fund managers
• Specialised investment funds (SIFs)
• Undertakings for collective investment in transferable securities (UCITS)
• Undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs)