Published on 18 March 2026 Communiqué

Communication to the investment fund industry

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

The Law of 3 March 2026 (the “2026 Law”) has been adopted to transpose Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024 (“AIFMD II”/”UCITS VI”) into Luxembourg law. In this context, additional liquidity management requirements have been introduced for UCITS, or where applicable their management company, and authorised AIFMs that manage open-ended AIFs with effect as from 16 April 2026. UCITS, or where applicable their management company, and AIFMs shall select 1 at least two 2 liquidity management tools (“LMTs”) from those referred to in Annex III, points 2 to 8 of the Law of 17 December 2010 relating to UCIs, as amended by the 2026 Law (the “2010 Law”) or Annex V, points 2 to 8 of the Law of 12 July 2013 on AIFMs, as amended by the 2026 Law (the “2013 Law”). This selection shall be made after assessing the suitability of those LMTs in relation to the pursued investment strategy, the liquidity profile and the redemption policy of the UCITS or AIF. It shall not be possible for that selection to consist only of swing pricing and dual pricing.

UCITS, or where applicable their management company, and authorised AIFMs that manage open‑ended AIFs shall include their selection of available LMTs in the fund or AIF rules, or in the instruments of incorporation of the UCITS or AIF. Moreover, in accordance with Annex I, Schedule A, point 1.13 of the 2010 Law and Article 21(1) of the 2013 Law, the disclosure of the selected LMTs shall be reflected in the UCITS prospectus or, for AIFs, as part of the information provided under Article 21 of the 2013 Law.

UCITS, or where applicable their management company, and authorised AIFMs managing open-ended AIFs shall also implement detailed policies and procedures for the activation and deactivation of any selected LMT and the operational and administrative arrangements for the use of such tool. UCITS, or where applicable their management company, and authorised AIFMs managing open-ended AIFs shall communicate to the CSSF their selection of LMTs, along with detailed policies and procedures governing their activation and deactivation. They shall also provide information on actual activations or deactivations of LMTs, in accordance with the provisions of the 2010 and 2013 Laws.

In this context, the CSSF hereby informs market participants of the launch of a dedicated “ Liquidity Management Tool ”  eDesk procedure, for the digital communication to the CSSF of the LMT-related information required under the 2010 and 2013 Laws. This eDesk procedure comprises two modules:

1. the “LMT selection” module, which will be launched on 23 March 2026. It will require 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. This information must be communicated to the CSSF by 16 April 2026. After the initial communication and in case of amendments, UCITS and authorised AIFMs remain responsible for ensuring that the information provided is kept up to date;

2. the “LMT activation” module, which will be launched on 16 April 2026. It will require UCITS or where applicable their management company, and authorised AIFMs to notify to the CSSF, as from that date, the activation/deactivation 3 of:

• suspensions of redemptions, repurchases and subscriptions;
• 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 activations or deactivations of LMTs they provide through the eDesk procedure will be subsequently used to notify the required competent authorities, ESMA and the ESRB in accordance with the provisions of the 2010 and 2013 Laws.

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 redemptions, repurchases and subscriptions, as well as the creation of side pockets, as required under the respective sectoral laws under the “LMT activation” module.

At this stage and until further communication, the CSSF is maintaining, for UCITS and AIFs under its supervision, its administrative practice regarding suspensions of redemptions, repurchases and/or subscriptions, as well as side pockets. UCITS, or where applicable their management company, and authorised AIFMs must therefore continue to follow the usual procedure with the relevant supervisory department and simultaneously use the “LMT activation” module for the sole notifications as described above.

Finally, the eDesk procedure will be developed further, notably to reflect the CSSF’s administrative practice with regards to suspensions of redemptions, repurchases and/or subscriptions, as well as side pockets. Further details on the timing and practical proceedings of the tool will be communicated at a later stage.

1 Suspensions of redemptions, repurchases and subscriptions, as well as side pockets, are LMTs available in any circumstances to UCITS, or where applicable to their management company, and AIFMs. These LMTs shall only be used in exceptional cases where circumstances so require and where justified having regard to the interests of the UCITS and AIF investors.

2 By way of derogation, only one LMT from those referred to in Annex III of the 2010 Law or Annex V of the 2013 Law, points 2 to 8, respectively may be selected for money market fund authorised in accordance with Regulation (EU) 2017/1131 of the European Parliament and of the Council.

3 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)