CSSF AIFM Reporting Dashboard: Benchmarking Your Annex IV Filing

ByOfficer

On 15 July 2026 the CSSF published its AIFM Reporting Dashboard covering the position as at 31 December 2025. The document aggregates the Annex IV returns that authorised and registered AIFMs file, and it is the closest thing the Luxembourg alternative fund sector has to a public benchmark. The CSSF AIFM reporting dashboard adds no obligation and leaves your filing duties untouched. If your fund sits a long way from the peer band on average size, leverage or investor mix, that gap is worth a second look before your next return goes in.

The 2025 edition maps EUR 2,734 billion of net asset value across 11,112 AIFs managed by Luxembourg AIFMs, split finely enough by strategy to catch a mis-keyed field. This note covers what it measures and how to read it against your own Annex IV data.

Related reading: CSSF Reporting Calendar Q2 2026

Scope and population: what the dashboard includes

The dashboard aggregates AIFMD data reported as at 31 December 2025, built on end-of-year returns. The population is AIFs managed by Luxembourg AIFMs, split between registered AIFMs under Article 3 of the Luxembourg Law of 12 July 2013 on alternative investment fund managers, which report a narrower dataset, and authorised AIFMs under Article 5, which carry the wider obligation. The reporting sits on Article 24 of Directive 2011/61/EU and the Annex IV template in Commission Delegated Regulation (EU) No 231/2013.

The scope point trips people up. The dataset keys off the manager. A Luxembourg AIF managed by an AIFM in another Member State does not appear here, because that AIFM files its Annex IV return with its own home supervisor. The dashboard confirms it: 94 percent of the NAV it covers (EUR 2,576 billion) sits in Luxembourg-domiciled AIFs, with EUR 158 billion in funds domiciled elsewhere and still managed from Luxembourg. So the total reads on the Luxembourg management industry, not on every fund with a Luxembourg address.

Section 5 covers a separate population that should never be added to the headline total: non-EU AIFMs marketing into Luxembourg under the National Private Placement Regime of Article 42 AIFMD, 1,601 AIFs with a combined NAV of EUR 1,726 billion, with the largest single origin being the United States (46 percent of the NPPR population). Adding it to the LU total would double-count the market.

The headline numbers for the Luxembourg AIF market

Total NAV grew about 10 percent over the year, continuing a run from 5,507 sub-funds and EUR 908 billion in 2019 to 11,112 AIFs and EUR 2,734 billion at end-2025. The strategy mix carries the detail:

  • Private equity (PEQF) leads at EUR 916 billion, roughly a third of total NAV, up 15 percent and at a new high.
  • Other AIFs (OTHR), mainly debt funds, reached EUR 878 billion (32 percent), up 9 percent.
  • Funds of funds (FOFS) stand at EUR 558 billion (20 percent), up 12 percent.
  • Real estate (REST) is EUR 338 billion (12 percent), up 2 percent.
  • Hedge funds (HFND) rose fastest at plus 16 percent but stay marginal at EUR 43 billion, just 2 percent of NAV.

The size distribution is the figure I reach for first. The mean AIF holds EUR 246 million, but the median is only EUR 62 million, with the quartiles at EUR 17 million and EUR 196 million. So 61 percent of AIFs managed by Luxembourg AIFMs have a NAV below EUR 100 million, and the sector is concentrated: 5 percent of the largest AIFs carry 49 percent of the NAV. A fund reporting an average sub-fund size an order of magnitude off that spread should have its NAV field checked for the right unit before filing.

Reading the strategy and leverage columns without misfiling

Leverage rewards careful reading, because the AIFMD asks for it on two bases that diverge sharply. Across all Luxembourg AIFs, gross-method leverage sits at 125 percent of NAV and commitment-method leverage at 113 percent. Hedge funds are the visible exception at 446 percent gross and 308 percent commitment, reflecting their heavier use of derivatives and securities financing. Sector financial leverage has risen to EUR 188 billion, around 70 percent of NAV for hedge funds and low elsewhere.

The two figures answer different questions. The gross method sums the absolute value of every position after converting derivatives to their equivalent underlying, and excludes base-currency cash. The commitment method allows netting and hedging offsets and includes cash. Both are required in Annex IV, so reporting a commitment figure in a gross field, or the reverse, is a common data-quality slip that the peer bands make easy to spot.

Portfolio composition gives a second anchor. The 2025 top exposures are shares of undertakings for collective investment at EUR 1,139 billion, unlisted equities at EUR 707 billion, other loans at EUR 321 billion, FX derivatives for hedging at EUR 303 billion and commercial real estate at EUR 129 billion, with Europe dominant. For funds booking derivatives in the same systems they use for EMIR transaction reporting, the FX line checks that hedging positions are captured consistently across both regimes.

Using the benchmarks to sanity-check your own Annex IV return

The dashboard earns its keep as a pre-submission reasonableness test. The CSSF runs data-quality controls on Annex IV filings, and the file credits part of the 2025 improvement in reported liquidity to those controls and to managers reflecting liquidity management tools more accurately. Cleaner data shows up in the aggregate, which flags where your own figures stand out.

Two data points read as quiet warnings. On the investor side, 96 percent of AIF investors are professional and the top five investors account for 86 percent of NAV on average, a concentration the CSSF says partly reflects a lack of look-through to beneficial owners in some reports. If your investor concentration looks unusually high, the cause may be an incomplete look-through in the return rather than a genuinely narrow investor base. On liquidity, 31 percent of NAV sits in open-ended AIFs and the aggregate liquidity shortage has fallen to about 2 percent of NAV, its lowest since 2019. A fund reporting a large mismatch against that norm stays fully compliant, yet it is the kind of outlier the CSSF controls are built to query.

Treat a benchmark as a reference and nothing more. Sitting outside the peer band carries no compliance consequence by itself; it just prompts you to confirm the figure is real before a supervisor asks about it. Administrators closing several managers at once can also use the strategy splits to confirm each fund is mapped to the right AIF type, since a mis-tagged vehicle distorts both its own return and the sector picture.

Annex IV filing: who reports, how often, and by when

The dashboard is descriptive, but the returns behind it run on a fixed calendar. Reporting frequency is set by Article 110(3) of Delegated Regulation (EU) No 231/2013 and keys off assets under management:

  • Annual, as at 31 December, for AIFMs whose total AIF assets are below EUR 100 million, and for unleveraged portfolios below EUR 500 million with a five-year lock-up.
  • Half-yearly, as at 30 June and 31 December, for portfolios between EUR 100 million and EUR 1 billion (or EUR 500 million to EUR 1 billion where unleveraged with a lock-up).
  • Quarterly, as at 31 March, 30 June, 30 September and 31 December, for portfolios above EUR 1 billion.
  • Any individual leveraged AIF above EUR 500 million is reported quarterly for that fund, even where the manager otherwise reports half-yearly.
  • An AIFM managing only unleveraged AIFs that invest in non-listed companies to acquire control reports annually.

Returns are due within one month of the period end, so annual reporters file by 31 January. AIFMs managing funds of funds may take an additional 15 days under Article 110(1) where they notify the supervisor. In Luxembourg the returns are filed with the CSSF under Circular CSSF 23/844, which sets out the current AIFM reporting obligations and replaced Circular CSSF 14/581. Sub-threshold managers should not expect their return to mirror the dashboard’s full risk profile, which is drawn from authorised AIFMs alone. Our CSSF reporting calendar maps the deadlines quarter by quarter, and the operational angle sits in our DORA checklist for Luxembourg fund administrators.

Frequently Asked Questions

Whose data is included, and whose is left out?

It covers AIFs managed by Luxembourg registered and authorised AIFMs. Luxembourg AIFs managed by an AIFM in another Member State are excluded, because that AIFM reports to its own home supervisor. Non-EU managers marketing under the NPPR sit separately in section 5.

Does the dashboard create any new reporting obligation?

No. It is a statistical publication that aggregates existing Annex IV data. The obligations come from Article 24 of the AIFMD and Delegated Regulation 231/2013, and they are unchanged by the dashboard.

How do I know which reporting frequency applies to me?

Frequency follows Article 110(3) of Delegated Regulation 231/2013 and is calculated across all EU AIFs you manage and market in the Union. The thresholds are EUR 100 million, EUR 500 million for certain unleveraged portfolios, and EUR 1 billion, mapping to annual, half-yearly and quarterly reporting.

Why are the gross and commitment leverage figures so different?

They use different methods. Gross leverage sums all positions with derivatives converted to underlying exposure and excludes base-currency cash. Commitment leverage allows netting and hedging offsets and includes cash. Both are required in Annex IV, so the columns should differ and should never be swapped.

Is it a problem if my fund is an outlier against the benchmark?

Not by itself. The dashboard is a reference, not a limit. An outlier is a reason to re-check the underlying figure and its unit before filing, especially average fund size, investor concentration and the two leverage columns.

Related Articles

Key Takeaways

  • The CSSF AIFM reporting dashboard for December 2025 aggregates EUR 2,734 billion of NAV across 11,112 AIFs managed by Luxembourg AIFMs, as at 31 December 2025.
  • It measures the Luxembourg management industry, not fund domicile: AIFs run by non-LU AIFMs are excluded, and the NPPR population in section 5 is separate.
  • Private equity leads at EUR 916 billion, other AIFs at EUR 878 billion, funds of funds at EUR 558 billion, real estate at EUR 338 billion and hedge funds at EUR 43 billion.
  • The median AIF holds EUR 62 million and 61 percent are below EUR 100 million, so average-size outliers are worth a unit check.
  • The dashboard changes nothing you file; Annex IV frequency and content are set by Article 24 AIFMD and Article 110 of Delegated Regulation 231/2013, filed under Circular CSSF 23/844.

Sources and References

Treat the dashboard as your reasonableness check

The December 2025 edition is a clean read of a EUR 2,734 billion market still growing on private equity and debt, and it is most useful the week before you file. Set your own Annex IV figures next to the strategy, size, leverage and liquidity bands, and let the peer norms flag anything worth a second look. The aim is simple: report the number you mean.

Last updated: July 2026

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.

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