CSSF AIF and ELTIF Marketing Notification: What Luxembourg AIFMs Must File

Last updated: June 2026

A marketing notification the CSSF treats as incomplete does not start the statutory clock. The AIF and ELTIF marketing notification file sits in the queue, the twenty working day period does not begin to run until the file is complete, and the launch date a distribution team promised the manager can slip by a fortnight. That failure mode usually traces to one of two things: an outdated form, or a notification letter sent without the documentation that makes the file complete.

The CSSF document page for the “Notification letter for the marketing of units or shares of EU AIFs/ELTIFs in Member States and/or home Member State of the AIFM” currently shows Version 1.4, published on 25 June 2024 and updated on 11 June 2026. It is the form a Luxembourg AIFM uses to notify marketing of an EU alternative investment fund or a European long-term investment fund under the AIFMD passport framework. The legal anchors remain Articles 31 and 32 of Directive 2011/61/EU and Article 31 of Regulation (EU) 2015/760.

Related reading: AIFMD II Annex IV reporting changes

The current AIF and ELTIF marketing notification template

The CSSF document page currently shows Version 1.4 of the notification letter, published on 25 June 2024 and updated on 11 June 2026. It is a Word template of about 158 kilobytes. The page identifies the version and the update date, but does not provide a line-by-line change log.

With no published change log, the safe assumption is that any field or cross-reference inside the letter could differ from the copy saved on a shared drive. The discipline is unglamorous: pull the current template from the CSSF page for each notification rather than reusing last quarter’s file. Where teams get this wrong is treating the version date as cosmetic. A filing made on a superseded form risks a CSSF query or resubmission request, and that can delay the point at which the file is treated as complete.

The legal basis: AIFMD Article 31, Article 32, and ELTIF Article 31

The form serves two routes under Directive 2011/61/EU. Article 31 governs marketing an EU AIF in the AIFM’s home Member State; Article 32 governs marketing it in other Member States, the cross-border leg most managers care about. The letter carries both, which is why its title references Article 31(2) and Article 32(2) together. The third anchor is Article 31 of Regulation (EU) 2015/760, which does not invent a separate passport: it routes ELTIF marketing back through the AIFMD machinery, with home Member State marketing notified under Article 31 and other Member States under Article 32.

This notification is not an authorisation. The AIFM is already authorised and the fund already exists; the notification tells the supervisor that an authorised manager intends to market a specific fund and gives the CSSF the file it needs to verify continued compliance. The CSSF is checking compliance, not granting a licence.

What belongs in a complete notification file

The letter is one document inside a larger file. For cross-border marketing, Annex IV to the Directive lists what travels with it: a notification letter that includes a programme of operations identifying the AIFs and where they are established; the AIF rules or instruments of incorporation; identification of the depositary; a description of, or information on, the AIF available to investors; for a feeder AIF, where the master is established; any additional information referred to in Article 23(1); the Member State of intended marketing; and information about the marketing arrangements, including any made to prevent the fund reaching retail investors. For home Member State marketing, Annex III carries the same list without the host Member State indication.

The common error is sending the letter and treating the annex items as attachments to follow. They are not a courtesy bundle; they are the content the CSSF assesses, and a file missing the depositary identification or the marketing arrangements is incomplete. A team that keeps a current CSSF reporting calendar beside its notification tracker catches these gaps before a CSSF query.

The twenty working day clock and when marketing can start

The two routes resolve differently, and conflating them is a reliable way to misjudge a go-live date. For home Member State marketing under Article 31, the CSSF has twenty working days after receiving a complete file to tell the AIFM whether it may start; on a positive decision, marketing in Luxembourg may begin from the date of that notification. For other Member States under Article 32, the model is transmission: no later than twenty working days after a complete file, the CSSF transmits it to each target authority with a statement of the manager’s authorisation, then notifies the AIFM, who may start marketing in the host state from the date of that transmission notification.

The point teams miss is where the statutory deadline starts: the twenty working day period runs only after the CSSF has received a complete notification file, not merely after the first submission. If the CSSF treats the file as incomplete, the practical effect is that the Article 31 or Article 32 deadline should not be relied on until the missing information is provided. Article 32 also states that the letter and the authorisation statement must be in a language customary in the sphere of international finance, and that electronic transmission and filing must be accepted.

The ELTIF dimension changes the investor base

The investor base is where an ELTIF notification diverges from an AIF one. Under the Directive, an EU AIF on the passport is by default marketed only to professional investors, without prejudice to a Member State allowing retail marketing under Article 43. An ELTIF is built to reach retail: Article 31 of the ELTIF Regulation lets its manager market to professional and retail investors, and states that the competent authorities’ powers under Articles 31 and 32 of the Directive extend to marketing ELTIFs to retail and cover the additional ELTIF requirements.

That carries a consequence AIF-only teams overlook. The ELTIF Regulation gives the home authority an extra ground: beyond its Directive powers, the CSSF must also prevent the marketing of an ELTIF where the manager does not or will not comply with the ELTIF Regulation. A notification flawless on its AIFMD elements can still be stopped on an ELTIF-specific defect. Regulation (EU) 2023/606, applicable from 10 January 2024, amended the ELTIF Regulation and introduced important changes to the ELTIF framework, while Article 31 continues to permit marketing of ELTIF units or shares to professional and retail investors.

Related reading: AIFMD II liquidity management tools

Material changes, pre-marketing, and de-notification are different forms

The marketing notification letter is one instrument in a family that is easy to confuse, because the members all touch the same passport. A material change to anything in the notification carries its own obligation: under Article 31 and Article 32, the manager must give the CSSF written notice of a planned change at least one month before implementing it, or immediately after an unplanned change. That notice is a separate event from the original notification.

Two adjacent processes use entirely separate CSSF forms. Pre-marketing, added to the Directive as Article 30a by the cross-border distribution package (Directive (EU) 2019/1160 and Regulation (EU) 2019/1156, applicable from 2 August 2021), covers testing investor appetite for a fund not yet established or notified for marketing. De-notification, under Article 32a, is how a manager stops marketing arrangements in a Member State, and it triggers a thirty-six month bar on re-engaging in pre-marketing for the same or a similar fund. Neither is what the marketing notification letter does. The same control discipline used for Luxembourg fund-administrator compliance workflows belongs in telling these notification types apart before submission.

Frequently Asked Questions

Which version of the notification letter is current?

The CSSF document page currently shows Version 1.4 of the notification letter for marketing EU AIFs and ELTIFs, published on 25 June 2024 and updated on 11 June 2026. The page does not publish a line-by-line change log, so the practical step is to download and use the current template for each filing rather than reusing a saved copy.

Does the form set the legal deadlines or the passport procedure?

No. The procedure runs on Articles 31 and 32 of Directive 2011/61/EU and Article 31 of the ELTIF Regulation. The twenty working day window and the one month material-change notice are set by the Directive, not by the CSSF template, so a form version does not alter them.

When can a Luxembourg AIFM actually start marketing?

For home Member State marketing under Article 31, from the date the CSSF notifies a positive decision, within twenty working days of a complete file. For other Member States under Article 32, from the date the CSSF notifies the manager that it has transmitted the complete file to the host authorities, which it does no later than twenty working days after a complete file.

Is the notification letter on its own enough?

No. The letter is one item in the file. Annex IV for cross-border marketing and Annex III for home Member State marketing list the documentation that must accompany it, such as the AIF rules, the depositary identification, and the marketing arrangements.

How is an ELTIF notification different from an AIF notification?

An ELTIF can be marketed to retail as well as professional investors under Article 31 of the ELTIF Regulation, whereas an AIF on the passport is by default limited to professional investors unless a Member State permits retail marketing. The CSSF can also prevent ELTIF marketing where the manager does not comply with the ELTIF Regulation, a ground that does not apply to a plain AIF notification.

Related Articles

• AIFMD II Annex IV Reporting Changes – The Annex IV regulatory reporting filed after a fund is marketed.
• AIFMD II Annex IV Leverage Calculation Template – The fund-leverage methodology behind the Annex IV figures.
• AIFMD II Liquidity Management Tools – Liquidity tool selection and disclosure for open-ended funds.
• DORA Compliance Checklist for Luxembourg Fund Administrators – Operational resilience duties alongside fund distribution.
• CSSF Reporting Calendar Q3 2026 – Deadline mapping for Luxembourg supervisory reporting.

Key Takeaways

• The CSSF notification letter currently shown on the CSSF document page is Version 1.4, published on 25 June 2024 and updated on 11 June 2026; the legal procedure sits under AIFMD Articles 31 and 32 and ELTIF Regulation Article 31.
• The form serves Article 31(2) of Directive 2011/61/EU for home Member State marketing, Article 32(2) for other Member States, and Article 31 of the ELTIF Regulation for ELTIFs.
• The twenty working day window runs from a complete notification file; an outdated template or a missing Annex IV item can delay the point at which the file is treated as complete.
• An ELTIF can be marketed to retail investors, and the CSSF can prevent ELTIF marketing for non-compliance with the ELTIF Regulation, unlike a plain AIF notification.
• Pre-marketing under Article 30a and de-notification under Article 32a are separate forms, with a thirty-six month pre-marketing bar after de-notification.

Sources and References

• CSSF, Notification letter for the marketing of units or shares of EU AIFs/ELTIFs (Article 31(2)/32(2) of Directive 2011/61/EU and Article 31 of Regulation (EU) 2015/760), Version 1.4, published 25 June 2024, updated 11 June 2026: CSSF document page
• Directive 2011/61/EU (AIFMD), Articles 31 and 32 and Annexes III and IV, consolidated text on EUR-Lex: CELEX 32011L0061
• Regulation (EU) 2015/760 on European long-term investment funds, Article 31, consolidated text as at 10 January 2024 on EUR-Lex: CELEX 02015R0760-20240110
• Directive (EU) 2019/1160 on cross-border distribution of collective investment undertakings (introducing Articles 30a and 32a into the AIFMD): CELEX 32019L1160
• Regulation (EU) 2019/1156 on facilitating cross-border distribution of collective investment undertakings: CELEX 32019R1156
• CSSF, Pre-marketing by AIFMs: CSSF pre-marketing page
• CSSF, ELTIF: CSSF ELTIF page

Before your next notification leaves the building

The notification letter is a small document with a large failure surface. Nothing in the Directive has shifted, and the supervisor’s window only opens on a complete and conforming file. Pull the current Version 1.4 letter from the CSSF page, assemble the full Annex IV or Annex III file, settle whether the fund is an AIF or an ELTIF and which Member States are in scope, and confirm you are filing a marketing notification rather than a pre-marketing or de-notification form.

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.