AIFMD II Passport Notifications: New CSSF Templates From 31 July

ByRegReportingDesk

From 31 July 2026, a Luxembourg UCITS management company or authorised AIFM that notifies a cross-border management activity has to use a new set of forms. On 30 July 2026 the CSSF published updated notification-letter templates and confirmed that the earlier versions stop being valid the next day. The same cut-off applies to the eDesk module used to file these AIFMD II passport notifications and to the equivalent CSSF API route. A notification prepared for submission from that date should therefore be moved to the current template before filing.

The change traces back to the Law of 3 March 2026, which transposes Directive (EU) 2024/927, known as AIFMD II, into Luxembourg law. That directive widened the list of activities and services an investment fund manager (IFM) can carry out, so the notification letters that record what a manager passports into another EEA state had to be rebuilt to capture them. This is an administrative update to a familiar process, and it sits on top of a substantive licensing point that is easy to miss.

Related reading: CSSF IFM Notification of Ancillary Services to Third Parties

The dates that matter

  • 13 March 2024: Directive (EU) 2024/927 (AIFMD II) adopted.
  • 16 April 2026: EU Member States apply most AIFMD II transposition measures. ESMA must submit draft technical standards on the amended supervisory-reporting provisions to the Commission by 16 April 2027, and Directive (EU) 2024/927 remained under scrutiny for incorporation into the EEA Agreement as at 31 July 2026.
  • 3 March 2026: the Luxembourg transposition law is adopted.
  • 30 July 2026: the CSSF publishes the updated notification-letter templates and the updated IFM guidelines.
  • 31 July 2026: the updated templates become mandatory, and the existing eDesk module and S3 API solution are updated. Those transmission channels had already been mandatory since 22 April 2026.

How AIFMD II passport notifications change from 31 July

Two notification letters were reissued. The UCITS management company letter moves to Version 4.1 and covers a manager’s intention to pursue, in another Member State, the activities it is authorised for under Article 17(2) or Article 18(1) of Directive 2009/65/EC. The AIFM letter moves to Version 3.1 and covers the intention to manage AIFs established in a Member State other than the home Member State under Article 33(2) of Directive 2011/61/EU, or to establish a branch under Article 33(3). Both are dated 30 July 2026 and both are DOCX forms.

The filing channel keeps its shape. Cross-border management notifications and de-notifications continue to run through the dedicated CSSF eDesk module, or through the equivalent CSSF API solution built on S3 technology, and both were refreshed for the same 31 July go-live. From 31 July 2026, the CSSF requires the updated templates. Any notification not yet submitted by that date should therefore be checked and, where necessary, transferred to the current template before filing.

Why the templates changed: AIFMD II’s new activities

AIFMD II amended Article 6(4) of the AIFMD to let an authorised AIFM provide services beyond collective portfolio management. Two additions stand out: administering benchmarks under Regulation (EU) 2016/1011 and carrying out credit servicing under Directive (EU) 2021/2167. The directive made a parallel change to the UCITS Directive, expanding the services a UCITS management company can provide and passport to other Member States, including services that had previously been available only to authorised AIFMs under the AIFMD framework.

Because a manager can now be authorised for a broader menu, the notification letter has to state which of those activities it intends to carry on across a border. The reissue reflects the wider set of services rather than a rewrite of the Article 33 procedure, and it works alongside the directive’s other reporting changes, including the AIFMD II Annex IV reporting changes. The point of the update is that the receiving supervisor sees an accurate picture of the activity being passported.

Authorise in Luxembourg first, then passport

The CSSF closed its communication with the point that carries the most operational weight. To pursue a new AIFMD II activity, function or service in another Member State, the manager must first be authorised by the CSSF to provide that activity in Luxembourg. Filing a cross-border notification does not, on its own, extend the passport to something the manager is not yet licensed for at home.

This is where a manager can misread the sequence. The updated template makes the new services selectable, which can look like an invitation to tick the box and notify. The home authorisation is the gate. A manager that wants to administer benchmarks or provide new AIFMD II services in a host state needs the Luxembourg licence extension in place before the host-state notification means anything, and the CSSF assesses that extension separately from the passport file.

Which passport these letters cover

These two letters sit on the management side of the AIFMD and UCITS frameworks. The AIFM letter runs off Article 33, which governs managing AIFs in another Member State or opening a branch there. The UCITS letter runs off Articles 17 and 18, the branch and freedom-to-provide-services routes for a management company. Neither is the marketing passport, which lets a fund be distributed to investors in a host state under separate provisions, and which has its own CSSF marketing notification letter for AIFs and ELTIFs.

The communication also covers de-notifications, the withdrawal of a management passport a manager no longer needs. A manager that is rationalising its cross-border footprint files the de-notification through the same eDesk module, and it should use the current version of the process here too. Keeping the management and marketing passports separate in the filing log matters when a supervisor later asks which permissions are actually live.

Filing the updated notification through eDesk

The CSSF pairs the new templates with an updated technical document, the IFM guidelines on cross-border management notification and de-notification procedures, dated 22 April 2026 and reissued on 30 July 2026. That guidance is the reference for how the eDesk module and the S3 API handle a notification, and it is the first place to check when a field on the new letter is not self-explanatory. The same discipline that applies to the fund’s AIFMD II liquidity management tools applies here: read the current guidance before assuming the process is unchanged.

For a reporting team, the immediate task list is short. Retire all earlier local copies of the AIFM and UCITS management-notification letters, download the current Version 3.1 AIFM and Version 4.1 UCITS forms from the CSSF pages, and confirm that the filing workflow uses the current eDesk or S3 process before submitting. Where a planned notification names a new AIFMD II service, confirm the Luxembourg authorisation for that service is already granted before the file goes in.

Frequently Asked Questions

Does an in-flight notification started before 31 July 2026 have to be redone on the new template?

The CSSF states that the updated templates must be used from 31 July 2026. A file that has not yet been submitted is the exposed case: it should be transferred onto the current Version 3.1 AIFM letter or Version 4.1 UCITS letter and checked against the refreshed eDesk fields before filing, rather than sent on the superseded form.

Is this the marketing passport or the management passport?

The two reissued letters are management-passport notifications under Article 33 of the AIFMD and Articles 17 and 18 of the UCITS Directive. Marketing a fund to investors in another Member State runs on a different notification with its own template, so a distribution change is not covered by these forms.

Can a manager passport a new AIFMD II service straight away using the updated form?

Only after the CSSF has authorised that service in Luxembourg. The notification records an activity the manager is already licensed for at home; it does not grant the underlying permission. A benchmark administration or credit servicing activity needs the Luxembourg licence extension first.

What happens to the S3 API route?

The CSSF updated both the eDesk module and the equivalent CSSF API solution on S3 technology for the same 31 July date. A firm that files through the API rather than the eDesk front end should confirm its integration reflects the refreshed process before the next submission.

Where are the technical field-level instructions?

The CSSF identifies its IFM guidelines on cross-border management notification and de-notification procedures, updated on 30 July 2026, as the source of additional information and instructions for the module.

Does AIFMD II rewrite the Article 33 notification procedure?

The CSSF communication frames the change as updated templates to reflect new activities. The letters were rebuilt so a manager can declare the wider set of services AIFMD II allows, while the mechanics of notifying the home and host authorities follow the existing Article 33 and Article 17 or 18 routes.

Key Takeaways

  • Updated CSSF notification-letter templates are mandatory for cross-border management notifications from 31 July 2026; the previous versions are no longer valid.
  • The UCITS management company letter is Version 4.1 (Article 17(2) or 18(1) of Directive 2009/65/EC); the AIFM letter is Version 3.1 (Article 33(2) or 33(3) of Directive 2011/61/EU).
  • The eDesk module and the CSSF S3 API route were refreshed for the same 31 July go-live; rebuild any in-flight notification rather than filing a cached form.
  • The trigger is the Law of 3 March 2026 transposing Directive (EU) 2024/927 (AIFMD II), which added services such as benchmark administration and credit servicing for AIFMs and expanded the services available to UCITS management companies.
  • A new activity can be passported only after the CSSF authorises it in Luxembourg; the notification does not create the underlying permission.
  • These are management-passport letters under Article 33 and Articles 17 and 18, separate from the marketing passport, which has its own notification.
  • Additional information and instructions for the eDesk module and S3 API are in the CSSF IFM guidelines on cross-border management notification and de-notification procedures, reissued 30 July 2026.

Sources and References

What to do before your next cross-border filing

Treat 31 July 2026 as the mandatory switch to the updated templates. The eDesk portal and S3 API solution were already the mandatory transmission channels from 22 April 2026 and were updated on 31 July 2026. Before the next management notification or de-notification leaves the desk, confirm three things: the letter is the current Version 3.1 AIFM or Version 4.1 UCITS form, the eDesk or S3 route reflects the refreshed process, and any new AIFMD II service named in the file is already authorised by the CSSF in Luxembourg. The next file that names benchmark administration or credit servicing is the one to check first.

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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