Circular CSSF 24/856 Feedback Report: Where Notifications Fell Short

On 5 October 2026 the CSSF published its first feedback report on Circular CSSF 24/856, the circular that has governed since 1 January 2025 how Luxembourg UCIs and their investment fund managers (IFMs) correct and notify NAV calculation errors, breaches of investment rules and a new class of “other errors”. The report works through the 2,218 notifications the CSSF received in 2025 and names where those filings fell short: incidents parked in a catch-all category, tolerance-threshold analyses without depth, fee breaches left open for more than two years, and pre-notifications used outside the cases the Circular allows.

The CSSF’s communication of the same day says all entities within the scope of the Circular are expected to give due consideration to these observations when preparing and submitting notifications. The first consequence is mechanical. Point 155 of the Circular says the CSSF refuses incomplete notifications and requires a new, completed one without delay, and the report separately records that a number of 2025 filings were cancelled for submission errors, with filings made under the wrong circular cancelled and the entities asked to resubmit them under the right framework.

I read the report as the CSSF’s working interpretation of its own circular after one full year of data. For the IFM, the UCI administrator and the fund board that owns the error policy, it sets out in concrete terms what a notification should look like when it lands in eDesk.

Related reading: CSSF Illiquid Asset Valuation Review: What Luxembourg IFMs Must Address

Circular CSSF 24/856 dates that frame the feedback report

The report reviews one calendar year of filings under a regime that switched on at a fixed date, so the calendar shapes how the statistics read.

• 28 March 2024: date of Circular CSSF 24/856 on the protection of investors in case of an NAV calculation error, an instance of non-compliance with the investment rules and other errors at UCI level.
• 24 December 2024: version 1 of the CSSF FAQ on Circular CSSF 24/856.
• 1 January 2025: the Circular enters into force and Circular CSSF 02/77 is repealed. Errors detected from that date are notified through the new eDesk forms or the S3 channel.
• July 2025: version 1.2 of the CSSF user guide “UCI notification in accordance with Circular CSSF 24/856: Practical and technical guidance”.
• 5 October 2026: publication of the CSSF feedback report and the accompanying communication.

Three running clocks sit inside the Circular. Point 158 sets the notification deadline at 4 to 8 weeks at the latest after detection for an error that does not entail compensation to investors, and requires more complex cases involving compensation to a great number of investors in different jurisdictions to be reported within the same window, with the compensation date supplied later. Point 157 expects the special report of the approved statutory auditor (the REA), where one is required, within 3 months of the complete notification, in principle. Point 158 also asks the notifying entity to report the progress of compensation payments monthly, and to give monthly updates on any special report that cannot meet the 3-month mark.

Scope is wider than the old regime. The Circular applies in full to UCITS, Part II UCIs, SIFs and SICARs, and extends, in whole or in part and without the auditor chapter, to Luxembourg ELTIFs, money market funds, EuVECAs and EuSEFs that are not UCITS, Part II UCIs, SIFs or SICARs but for which the CSSF is the competent authority. Errors detected before 1 January 2025 stayed under Circular CSSF 02/77, which is why 190 of the notifications the CSSF received in 2025 still arrived under the old circular.

What 2,218 notifications in 2025 show

Of the 2,218 notifications received in 2025, 190 were filed under Circular CSSF 02/77 and 2,028 under Circular CSSF 24/856. The report’s overall split by type looks like this.

Three features of that table matter for anyone who files these notifications. NAV calculation errors are the smallest bucket, and that count only includes errors at or above the tolerance threshold in Chapter 4.2. The breach count only includes active breaches: point 55 of the Circular keeps passive breaches, those caused by events beyond the fund’s control such as market moves, out of the notification perimeter. And the “other errors” category, which did not exist under Circular 02/77, produced 586 notifications in its first year, more than twice the number of NAV errors.

Inside the breach bucket, 573 notifications (41%) concerned investment policy limits set in the fund’s own offering document or prospectus, which the report describes as the main category in previous years too. Of those 573, 210 related to ESG limitations that operate as binding investment restrictions. Breaches of UCITS diversification, holding and borrowing limits added 565 cases and UCITS eligibility rules 77. The single most cited legal limit was Article 43(1) of the Law of 17 December 2010, which carries the 10% single-issuer limit for transferable securities and the 20% limit on deposits with one body, with 310 notifications, followed by the 10% temporary borrowing limit in Article 50(2) with 119.

The root causes the CSSF lists for the ESG cases are operational. Internal controls or system settings were not updated after the fund documentation changed, or were not adequate to begin with. Portfolio management decisions overrode pre-trade alerts without adequate justification, misread system warnings, or sold positions until exposure fell below a required minimum level. And avoidable data issues degraded the accuracy of the restriction checks.

The “Other error” sub-category drew the first criticism

Of the 239 NAV calculation errors, 82 were filed under the sub-category “Other error (please describe further in the field ‘Description and cause of the NAV error’)”, more than any defined type. Accounting errors followed with 58 and securities valuation errors with 35; fees and accruals, derivatives valuation and corporate action errors made up the rest. The CSSF accepts that classification is not always straightforward, but concludes that the sub-category was used excessively as a default and that an assessment of the incident and its root cause would have allowed a more appropriate classification.

The expectation is set in the report’s own words: the processes of UCIs, IFMs and UCI administrators must ensure that “Other error” is only used when none of the predefined categories adequately reflects the nature of the error. The classification choice becomes something the error process itself has to control.

The second classification problem crosses chapter boundaries. Some incidents notified as NAV calculation errors were really departures from the offering document. The report’s example is a currency-hedged share class that was hedged incorrectly for a specific currency exposure. The CSSF treats that as non-compliance with the hedging policy disclosed in the prospectus, to be notified on the eDesk form “Non-compliance with investment rules at UCI level”.

The choice of chapter changes the arithmetic. A breach under Chapter 5 is corrected and the fund compensated without applying the NAV tolerance thresholds (point 71), using the accounting or economic method in Section 5.5. A separate check under Section 5.6 then asks whether the breach also produced a significant NAV error on any NAV during the breach period. I read the hedged share class example as a sequencing rule: test first whether the incident is a departure from a rule in the prospectus, and only then treat it as a calculation problem.

Tolerance thresholds: Table 3 is the reference, 5% is the ceiling

Chapter 4.2 fixes the thresholds for every money market fund and UCITS in scope, and by default for Part II UCIs and ELTIFs open to retail investors. Money market funds use 0.20% of NAV (Table 1). UCITS (Table 2), and Part II UCIs and ELTIFs whose units can be held by investors that are not well-informed or professional (Table 3), use 0.50% for bond and mixed funds and 1.00% for equity funds and funds investing primarily in other assets.

Two routes allow a fund to move away from those tables, and the report found a number of the supporting analyses wanting. Retail Part II UCIs and ELTIFs that invest primarily in other assets, such as unlisted shares, buildings, loans or ELTIF-eligible investments, may by derogation set a threshold above 1% if the fund’s characteristics, including its risk profile, justify it on the basis of a specific well-documented analysis. Part II UCIs and ELTIFs reserved to well-informed or professional investors, together with SIFs, SICARs, EuVECAs and EuSEFs (money market funds excepted), set their threshold through the qualitative approach in point 35(d), with Table 3 as the reference and a ceiling of 5% of NAV.

The report spells out what the analysis must contain: objective and verifiable criteria, a stated rationale for the threshold chosen, all relevant factors (investment strategy, nature and liquidity of the assets, valuation risks, operational considerations and any other relevant characteristic), and both quantitative and qualitative support that demonstrates the threshold is appropriate. It then records that a number of the requests submitted in this context did not meet those expectations, and that the analysis in particular lacked sufficient depth and consistency.

The 5% figure works only as a cap. Point 35(d)(iii) states that no UCI may use 5% by default and that the analysis must be made available to the CSSF, which can ask for it at any time. Point 35(d)(ii) adds that the CSSF expects professional-investor funds whose policies resemble those in Table 3 to use similar thresholds. On my reading, a professional-investor bond fund sitting at 5% therefore needs an analysis that explains its distance from the 0.50% reference. The Circular also requires investors to be informed of any threshold above Table 3 through the fund’s official and usual communication channels.

Two mechanical rules from point 37 sit underneath all of this. For an umbrella fund the threshold is set per sub-fund, with a single threshold for all share classes in that sub-fund, and it must be determined on a documented basis before the first NAV is published.

Semi-liquid Part II UCIs count as open-ended

Closed-ended UCIs fall outside Chapter 4, so they have no Circular tolerance threshold and do not notify NAV calculation errors to the CSSF under Chapter 9 (point 27). The definition therefore carries weight. A closed-ended UCI is any UCI that is not open-ended, and an open-ended UCI is one whose units are repurchased or redeemed, at the request of any unit-holder, before its liquidation or dissolution phase, out of the UCI’s assets and in line with the arrangements and frequency set in its constitutive documents or prospectus. UCITS and money market funds cannot be closed-ended.

After questions from the industry, the report clarifies that UCIs offering limited redemption possibilities, such as semi-liquid Part II UCIs, fall into the open-ended category and are subject to Chapter 4, including the guidelines on tolerance thresholds. Read with the definition, infrequent dealing dates or redemption restrictions leave a fund inside the notification perimeter for significant NAV errors, as long as unit-holders can ask for redemption before liquidation.

Closed-ended funds keep a set of duties of their own. Point 26 and the first paragraph of point 27 still require ongoing compliance with the NAV calculation rules and valuation policies that limit and detect errors, the fund or its IFM must correct NAV errors where appropriate, and the REA verifies in the statutory audit that the NAV reflects the value of the assets and liabilities. The CSSF FAQ recommends an internal tolerance threshold for closed-ended UCIs to identify errors that need correcting, and confirms that a fund with such an internal threshold stays outside Chapter 9 notification when that threshold is crossed.

Semi-liquid funds also have a separate notification route when they suspend redemptions, set out in our article on the CSSF LMT activation module for redemptions-only suspensions.

Investment breaches: the economic method is gated by the policy

On breach handling the CSSF opens with a positive finding: UCIs generally have sound policies, processes and procedures to keep investments within legal, regulatory and contractual limits. The accounting method, the Circular’s default under point 79, was used in 1,380 of the 1,393 breach notifications. The economic method appeared in 13.

The friction sits in those 13 cases and around them. In most of them the economic method and its comparative reference were formally documented in the UCI’s internal policy, and the reference, a representative benchmark, was usually disclosed in the prospectus and applied consistently to the same type of breach. In some limited cases the method was not adequately foreseen in the internal policy and was applied anyway, in particular where the accounting method would have produced a loss for the fund. The CSSF intervened at the level of those entities.

The report restates the Circular’s conditions. The economic method can be used only where the internal policy formally provides for it together with a clearly defined comparative reference (point 85). That reference has to represent the fund’s investment policy, so the fund’s benchmark may qualify while an isolated asset presented as equivalent to the irregular investment cannot (point 83). A change of method needs a justification grounded in investors’ interests and approval by the UCI or IFM dirigeants (point 74), and as a matter of principle it is not permitted once a breach has been identified. The stated purpose is to prevent arbitrage between methods aimed at minimising compensation.

The report ends this part with a reminder on maintaining an up-to-date and effective investment compliance control framework to prevent breaches in the first place.

Other errors reach the CSSF whatever the NAV impact

The report opens its Chapter 6 observations by clarifying the notification rule. Other errors have to be notified under Chapter 9 irrespective of whether their financial impact exceeds the fund’s Chapter 4 tolerance threshold. The CSSF’s illustration is a bond fund with a 0.50% threshold that pays costs or fees above what its offering document provides. That payment is an “other error” under Section 6.2, and it is notified even where its impact stays below 0.50% of NAV.

Swing pricing is the stated exception: for those errors the report points to the notification, compensation and indemnification requirements in Table 6 of Chapter 6. In Section 6.1 of the Circular, the threshold decides whether investors are compensated, measured on the gap between the NAV per unit applied and the NAV per unit the correct swing factor would have produced, while a fund left under-protected from dilution is compensated for its loss either way. For managers already mapping anti-dilution tools under the AIFMD II liquidity management tools regime, point 100 extends the same treatment: errors in other dilution management tools, such as an anti-dilution levy or liquidity fees, are handled in a similar manner to swing pricing errors.

The 38 swing pricing notifications split into 21 “other swing pricing or anti-dilution” errors, 8 cases where the set swing factor was not applied, 5 where the factor applied was too high and 4 where it was too low. The CSSF traces most of them to human error: swing factors not updated after a decision of the IFM’s pricing committee, or incorrect swing pricing data entered in internal systems.

Cut-off errors follow a different logic. Point 109 excludes the tolerance threshold because a correctly calculated NAV was applied to the wrong orders, and point 108 requires every order executed at the wrong NAV to be corrected. Of 79 cut-off notifications, 64 involved errors with a negative impact on investors or the fund and 15 had no impact. The causes the report lists are processing delays, human error, technical or system failures, orders submitted in good order but processed incorrectly, and an incorrect dealing or holiday calendar. In a number of cases one error at the UCI administrator hit several UCIs and generated several notifications.

Costs and fees: 416 notifications and no de minimis

Non-compliant payment of costs or fees produced 416 of the 586 other errors, or 70.99%. In 326 cases the UCI paid too much and in 90 it paid too little.

The boundary with NAV errors is the payment itself. An accrual error that is never paid out stays a NAV question under Chapter 4 (point 102) and matters for notification only if it reaches the tolerance threshold. Once an accrual error turns into a payment error, Chapter 6 governs. Where that payment error is also large enough to cause a significant NAV error, the report says it is reported under Chapter 6 only, with no separate NAV notification, because the Chapter 6 form has fields for the NAV error. The CSSF FAQ gives the clean non-example: a management fee accrued at 1.8% instead of the prospectus 2%, corrected within the quarter before any payment and below the tolerance threshold, falls under neither Section 6.2 nor Chapter 4.

The CSSF ties many fee incidents to weaknesses in the control framework at the IFM, the UCI administrator or both: insufficient pre- and post-payment controls, overly manual processes, inadequate oversight of delegates, gaps in escalation and reconciliation, and remediation after earlier errors too weak to stop them recurring. Some UCI administrators filed a higher number of fee incidents than others, and in several cases a single processing error at one administrator spread across multiple UCIs.

Duration is where the report gets pointed. Of the 416 incidents, 289 (69%) lasted less than six months, 36 (9%) between six months and a year and 37 (9%) between one and two years. The remaining 54 (13%) stayed open or unresolved for more than two years. The CSSF asks the industry to put an appropriate control framework around the payment of costs and fees and to take remediation measures on a timely basis.

The de minimis question needs care, because two different ideas share the name. Section 7.2.2 of the Circular lets a fund leave unpaid any investor compensation that does not exceed a de minimis amount set in its policy to reflect bank transfer charges. Nothing in the Circular sets a floor below which a non-compliant fee payment escapes notification. Market participants asked about one during 2025. The CSSF’s answer is that the current framework has none and that every instance, irrespective of amount, must still be notified, while it assesses the framework in light of how many cases involve small amounts.

The report closes two further gaps. The notification duty covers every cost or fee whose payment does not comply with the constitutive documents or prospectus, including costs or fees the documents do not set out explicitly, because a fund may only pay a cost or fee those documents foresee. And where the UCI paid too little, 72 of the 90 cases did not lead to a retroactive charge to the fund; point 105 allows either that route, with the party at fault paying from its own assets, or a retroactive charge that requires full NAV correction over the whole error period without applying the tolerance threshold.

The fee section closes on a Chapter 7 reminder: compensation must be paid in full without delay, with no instalments and no offset against future remuneration owed to the party responsible for the error. Point 118, the provision the report cites, is written for compensation owed to the UCI, which must be transferred so the fund can benefit from it as soon as possible after the amount is determined. Point 117 carries the general rule that also covers investors: remediation of the loss without delay, and payment of the compensation once it has been quantified.

Investment allocation errors: one mistake, two notifications

The CSSF recorded 53 allocation errors in 2025: 25 where a UCI received an investment in error, 17 where a UCI did not receive the investment intended for it and 11 other cases. Its observations deal with four problems.

Some cases filed as allocation errors were purchases of instruments the UCI was not allowed to hold, which belong under Chapter 5 as investment breaches. Where an investment meant for UCI Y was booked to UCI X, both funds in scope of the Circular, the error hits X one way and Y the other, and the CSSF expects two notifications, each with its own analysis and correction for the fund concerned.

Several notifications reported a correction “without impact”. The CSSF’s position is that the impact of an erroneously allocated investment is measured by comparing the initial price paid or received with the market price applicable at the time of the correction. It does not accept a reallocation days or weeks later at the original price without assessing and calculating the impact at sub-fund level on applicable market prices. The determination follows, by analogy, the start-and-end-date rules in point 76 (Section 5.5.2) for active breaches.

The report treats a trade in the wrong instrument, such as buying the wrong security or selling a derivative where a purchase was intended, as falling outside Section 6.4 and every other error category in the Circular. Point 96 still requires the fund to assess at every occurrence whether corrective action and compensation are needed. Where such a material incident falls outside Chapters 4, 5 and 6, the CSSF asks to be informed by email at opc.sp.prud@cssf.lu and will consider whether the Circular and the eDesk forms should cover it.

The CSSF says it intends to bring further clarification on handling allocation errors, citing the different market practices it observed. No date is given.

Special auditor reports under the EUR 50,000 and EUR 5,000 triggers

Section 8.1 of the Circular (point 138) asks the REA of a UCITS or Part II UCI to perform an additional control, ending in a special report to the UCI dirigeants and the CSSF, where total compensation exceeds EUR 50,000 or compensation to a single investor exceeds EUR 5,000. Under Circular 02/77 the triggers were EUR 25,000 and EUR 2,500. The total counts compensation paid to the fund and to all investors together, and the control must be performed immediately after detection, with the REA informed without delay.

In 2025, 29 cases required a special report under Circular 02/77 and 76 under Circular 24/856. Among the 76, NAV calculation errors were the most frequent trigger with 25, followed by cut-off errors (15), investment breaches (14), costs and fees (14), swing pricing (5) and allocation errors (3). Taken together the four types of other errors accounted for 37 of the 76. The CSSF notes that only a very limited number of special reports pointed to issues or exceptions, which it followed up.

The filing mechanics run through the same notification record. After a complete notification, eDesk creates a new version with an “Actions required” status, and the special report is uploaded from the “Documents” menu of that version. Point 157 expects it within 3 months of the complete notification, in principle, and the REA’s fee for it is a correction cost that cannot be charged to the fund (points 133 and 134).

SIFs and SICARs do not trigger special reports. Their errors are covered by sample-based review in the REA’s annual separate report, whatever the amounts (Tables 9 to 11). One detail in Table 10 is easy to miss: for an active investment breach at a UCITS or Part II UCI, the EUR 5,000 single-investor trigger applies where the breach also exceeds the NAV tolerance threshold.

eDesk filing quality: cancellations, wrong regime, pre-notifications

The industry welcomed the move of the notification forms into eDesk, according to the report, citing ease of use and a secure channel. The filings themselves showed room for improvement. Some were cancelled for submission errors such as the wrong sub-fund, the wrong form or duplicate filings. Others were insufficiently detailed, unclear, inaccurate or unrelated to the incident, including text copied from earlier notifications. Some contained inconsistencies in the regulatory framework selected, the identification data or the indemnification amounts.

The regime boundary caused its own cancellations. Errors detected before 1 January 2025 were filed under Circular 24/856 when they belonged on the Excel-backed template of Circular 02/77, and the reverse also happened. All were cancelled and the entities asked to resubmit under the right framework.

The CSSF expects notifications that are complete, accurate and detailed enough to explain the origin, causes and impact of the incident, and reminds entities to use the user guide and the tooltips in the eDesk forms. It names three pre-submission checks: the identification data of the sub-fund, the absence of duplicate submissions and the correctness of the indemnification data. The Circular adds that every field must be filled in and the form’s frame strictly followed (point 153), with a quantitative impact calculation attached (point 154). For entities filing through the S3 channel, the user guide specifies a JSON report in a ZIP archive that must include an IMPACT_CALCULATION_SHEET.xlsx for a complete notification, and a notification accepted through S3 cannot be modified by a new S3 submission, only through eDesk under certain conditions.

Pre-notifications get their own set of observations. The user guide, in its guidance for the NAV error form, frames the option as exceptional, for duly justified cases where the calculations and compensation processes are so complex and time-consuming that a complete notification cannot be filed within 4 to 8 weeks. Entities generally supplied the required information, but the report found that in a number of pre-notifications it was incomplete, insufficiently detailed or unrelated to complex cases, and that in a large number of those cases a pre-notification was made without meeting the Circular’s criteria. The CSSF expects pre-notifications to be complete, sufficiently detailed and used only for the complex cases described in point 158.

Two procedural points follow. Point 158 requires the notifying entity to keep the CSSF informed of compensation progress monthly; the CSSF is enhancing the eDesk pre-notification form to align it with the complete-notification workflow, and until then monthly updates go by email to opc.sp.prud@cssf.lu. And some entities, after the CSSF accepted their pre-notification, filed a fresh notification under a new reference number. The CSSF asks that accepted pre-notifications be finalised within the procedure already opened, under the original reference number.

What the feedback report leaves unchanged

The report leaves the text of Circular CSSF 24/856 as it stands, sets out observations that the CSSF expects entities to take into account when notifying, and flags two open policy items without dates, an assessment of the framework given the volume of small-amount fee breaches and further clarification on allocation errors, plus one pending system change, the eDesk pre-notification upgrade. Until either produces a change, the current text applies, including notification of every non-compliant fee payment.

The supervisory model around notifications also stays as it was. Under point 159 the corrective actions described in a notification are not subject to CSSF approval, and the CSSF does not send specific feedback on each notification; filings feed its risk-based supervision. Point 160 keeps the CSSF’s ex post options open: requesting more information, requiring different remedial action where the proposed actions depart from the Circular, or requiring improvements to organisational arrangements where notifications point to deficiencies.

The report fits a priority the CSSF had already announced. Its 2026 supervisory priorities for the investment fund sector, under the asset valuation heading, state that the CSSF will monitor the correct implementation of Circular CSSF 24/856 concerning NAV calculation errors, instances of non-compliance with the investment rules and other errors at UCI level.

Frequently Asked Questions

Does Circular CSSF 24/856 apply to a RAIF?

Only where it falls into one of the Circular’s categories. The CSSF FAQ on the Circular states that RAIFs are outside its scope unless they fall into one of the categories in Section 2.1 for which the CSSF is the competent authority, such as a Luxembourg ELTIF; points 2 to 4 of Section 2.1 set out how the Circular applies to ELTIFs, money market funds, EuVECAs and EuSEFs that are not UCITS, Part II UCIs, SIFs or SICARs. RAIFs have other notification touchpoints with the CSSF, covered in our guide to the CSSF fund notification forms under Circular 25/894.

Our internal policy sets a tolerance threshold below the Circular’s. Which threshold triggers notification?

The lower one. The CSSF FAQ answers that where the internally approved threshold is lower, all provisions of the Circular apply on the basis of that lower threshold. Point 36 of the Circular also requires a lower threshold, once chosen, to be applied consistently over time.

A significant NAV error occurred, but nobody subscribed or redeemed during the error period. Is a notification still needed?

Yes. The CSSF FAQ expects the source of the error to be identified and corrected so that the next NAVs are right, corrective actions such as stronger internal controls to be taken, and a notification to be sent that includes the source of the error and the measures taken to avoid a recurrence, even though no compensation is payable.

Do we need CSSF approval before applying a de minimis amount to investor compensation?

No prior approval is needed, according to the CSSF FAQ. The CSSF can ask ex post for justification of the level applied and documentary evidence that it reflects the bank charges of transferring compensation, in particular where the de minimis amount exceeds EUR 25. The rule never applies to compensation owed to the fund itself: point 127 requires every amount due to the UCI to be paid unless it is lower than one monetary unit.

A UCITS exceeded the expected level of leverage disclosed in its prospectus. Is that a notifiable breach?

The CSSF FAQ says no notification is required under Circular CSSF 24/856 for a UCITS exceeding the leverage level disclosed under box 24 of the CESR guidelines on risk measurement and the calculation of global exposure and counterparty risk for UCITS, or for a regulated AIF exceeding the leverage limits disclosed under Article 21(1)(a) of the Law of 12 July 2013. The CSSF still expects the situation to be monitored and corrected under internal procedures, including escalation.

The audit invoice came in higher than the audit fee accrued in the fund’s books. Is that a non-compliant payment of fees?

The CSSF FAQ treats that case as outside Section 6.2 where the accrual was booked on time, in good faith and on reliable information, and additional unplanned audit work raised the final fee. In that first worked example the fund pays the invoice and reverses the accrual.

Our fund is marketed in a country whose regulator imposes a stricter NAV tolerance threshold. What applies?

Point 37(v) requires the fund to retain the more restrictive threshold and to apply it to the whole UCI or sub-fund and to all its investors, wherever they are based, so that investors are treated equally. Point 161 separately requires the competent authorities of the marketing countries to be informed of errors in line with their own rules.

Related Articles

• CSSF Illiquid Asset Valuation Review: What Luxembourg IFMs Must Address: what the CSSF expects Luxembourg managers to fix in valuation policies, models, controls and escalation.
• CSSF LMT Activation Module: Notifying a Redemptions-Only Suspension: how Luxembourg UCIs, SIFs and SICARs notify a redemptions-only suspension through eDesk.
• AIFMD II Liquidity Management Tools: how the harmonised tools, selection duty and calibration standards work under Directive (EU) 2024/927.
• CSSF Fund Notification Forms: Filing Under Circular 25/894: the updated CSSF notification forms Luxembourg IFMs file for non-authorised funds.
• ESMA Risk Management Function CSA: The 2026-2027 Supervisory Review: how ESMA’s common supervisory action tests the risk management function of UCITS management companies and AIFMs.

Key Takeaways

• Build a classification gate into the error workflow: an incident caused by a departure from the prospectus goes to the Chapter 5 or Chapter 6 form, and the NAV “Other error” sub-category needs a recorded reason why no defined type fits.
• Re-open any tolerance threshold above the Table 3 level. The file should hold objective criteria, a rationale, quantitative and qualitative support and proof of investor communication, and the result can never exceed 5% of NAV.
• For a semi-liquid Part II UCI, check that each sub-fund has a Chapter 4 threshold documented before its first NAV, and that NAV errors at or above it are routed to the eDesk notification process.
• Treat every non-compliant cost or fee payment as notifiable, with no amount floor and no NAV threshold test, and pay any compensation owed to the fund in full in one transfer.
• When one allocation mistake touches two in-scope funds, file two notifications and price the impact at the market price on the correction date.
• Reserve pre-notifications for complex, multi-jurisdiction compensation cases, send monthly progress to opc.sp.prud@cssf.lu until the eDesk form is upgraded, and close the case under the original reference number.
• For a UCITS or Part II UCI, inform the REA without delay once total compensation passes EUR 50,000 or one investor’s compensation passes EUR 5,000.

Sources and References

• CSSF, Circular CSSF 24/856 Feedback Report (document page, published 5 October 2026): cssf.lu
• CSSF, CSSF Feedback Report on Circular CSSF 24/856 (PDF): cssf.lu
• CSSF, Communication on the CSSF Feedback Report on Circular CSSF 24/856 (5 October 2026): cssf.lu
• CSSF, Circular CSSF 24/856 on the protection of investors in case of an NAV calculation error, an instance of non-compliance with the investment rules and other errors at UCI level (document page): cssf.lu
• CSSF, Circular CSSF 24/856, English version (PDF): cssf.lu
• CSSF, FAQ on Circular CSSF 24/856, version 1 (24 December 2024): cssf.lu
• CSSF, UCI notification in accordance with Circular CSSF 24/856: Practical and technical guidance, version 1.2 (July 2025): cssf.lu
• CSSF, The CSSF’s 2026 priorities for supervising the investment fund sector (March 2026): cssf.lu
• CSSF, Law of 17 December 2010 relating to undertakings for collective investment (consolidated version): cssf.lu

Re-testing the 24/856 notification workflow before the next eDesk filing

The deadline stays the window of 4 to 8 weeks after detection in point 158, repeated in the user guide, with monthly updates on compensation still being paid, and the report’s expectations apply to the content filed inside that window. The artifact to update first is the error policy behind every notification, in three places: the classification logic that decides between Chapters 4, 5 and 6, the tolerance threshold analysis that the UCI dirigeants and the IFM own under point 35, and the pre- and post-payment controls on costs and fees that the CSSF linked to incidents left open for more than two years.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.