CSSF Branch Termination Annexes: What AIFMs and UCITS ManCos File

On 15 July 2026 the CSSF updated the two forms a Luxembourg fund manager reaches for when it closes a branch it had opened in another Member State: the CSSF branch termination annex under Article 33 of Directive 2011/61/EU (AIFMD), and its counterpart under Article 17 of Directive 2009/65/EC (the UCITS Directive). Both moved to Version 1.1, having first appeared on 16 February 2026. Each is a short DOCX filed through the CSSF eDesk portal, and each carries the label the CSSF uses across this family of forms: European passport.

The trigger for using them is narrow. A Luxembourg-authorised alternative investment fund manager, or a Chapter 15 UCITS management company, exercised the management passport to set up a branch in a host Member State, and now wants to wind that branch down. Closing a branch is a formal procedure: the manager files written notice of a change to the particulars already communicated when the branch was authorised, and the directive fixes both the notice period and the recipient.

Getting the recipient right is the part that separates the two regimes, and it is the point most worth checking before you submit on eDesk.

Related reading: CSSF AIF and ELTIF marketing notification letter

What changed on 15 July 2026

The CSSF keeps a separate termination annex for each passport regime. The AIFMD annex, covering termination of a branch under Article 33 of Directive 2011/61/EU, is a 114 KB DOCX flagged as relevant for alternative investment fund managers. The UCITS annex, covering branch termination under Article 17 of Directive 2009/65/EC, is a near-identical DOCX flagged for management companies under Chapter 15 of the Law of 17 December 2010. Both show a publication date of 16 February 2026 and an update to Version 1.1 on 15 July 2026.

The form’s administrative history: both annexes were first published on 16 February 2026 (Version 1.0) and refreshed to Version 1.1 on 15 July 2026. The dates that matter for an actual closure come from the directives. AIFMD Article 33(6) and UCITS Article 17(8) each require written notice at least one month before a planned branch closure is implemented. For context, AIFMD Article 33(4) and UCITS Article 17(3) gave the CSSF two months to transmit the opening notification to the host authority when the branch was first established. That is the opening-move timetable, included here so readers do not mistake it for a termination deadline.

The CSSF has not published a change log for the move from Version 1.0 to Version 1.1, so treat the update as a form refresh; the underlying obligation lives in the directives and has not shifted for this step.

Why a branch closure counts as a change of particulars

Neither directive has a standalone “close a branch” article. The mechanism runs through the change-notification paragraph instead. When a Luxembourg AIFM first sets up a management branch abroad, Article 33(3) of AIFMD has it communicate the branch’s organisational structure, the address from which documents can be obtained, and the persons responsible for running the branch. Shutting that branch alters every one of those particulars, so Article 33(6) governs the exit.

Article 33(6) reads that in the event of a change to the information communicated under paragraphs 2 and 3, the AIFM gives written notice to the competent authorities of its home Member State at least one month before implementing a planned change, or immediately after an unplanned change has occurred. A branch closure is almost always planned, which puts a firm in the one-month-ahead lane. The UCITS side mirrors the logic: Article 17(8) attaches to a change of the particulars notified under Article 17(2), points (b), (c) and (d), with the same one-month advance notice for the planned case.

So the termination annex is the CSSF’s standard vehicle for making that Article 33(6) or Article 17(8) notification. The obligation comes from the directive itself; the annex provides the form that obligation takes, which is why the timing and the addressee matter more than the document.

Who you notify: the AIFMD and UCITS split

Here the two regimes diverge, and the difference is easy to miss because the forms look alike. Under AIFMD Article 33(6), the AIFM notifies its home authority only. For a Luxembourg AIFM the home authority is the CSSF, which then informs the host authority of the change. The manager deals with one supervisor.

Under UCITS Article 17(8), the management company gives written notice of the change to the competent authorities of both its home Member State and its host Member State. A Chapter 15 ManCo closing a branch therefore has two recipients: the CSSF and the supervisor in the country where the branch sat. The line I would check first on any UCITS branch closure is whether the host authority actually received its copy, because the AIFMD habit of filing only with the CSSF does not carry across.

This asymmetry is written into the directives, so it holds whichever host Member State is involved. A firm running both an AIFM and a UCITS ManCo from the same Luxembourg platform applies two different notification maps to what feels like the same event.

Filing the annex through eDesk

The CSSF routes European passport notifications through its eDesk portal, and the termination annexes follow that path. The annex belongs to a wider passport file: on the AIFM side it is the closing bookend to the CSSF annex to the Article 33 notification letter and the letters identifying the persons responsible for the branch, all lodged when the branch was set up.

A branch closure is separate from de-registering the manager and separate from any change to the funds under management. If the manager is also winding down cross-border marketing of specific funds, that runs through the marketing de-notification route. Keep the two filings separate on eDesk.

What the branch termination annex does not cover

The annex has a tight perimeter, and reading it too broadly is the common error. Three boundaries are worth stating plainly.

It is an outbound form. It applies to a Luxembourg AIFM or ManCo closing a branch it established in another Member State under the passport. A third-country group closing an inbound branch in Luxembourg sits under a different authorisation regime, covered in our note on CRD6 third-country branch authorisation.

The form applies to branches only. Both directives let a manager passport into a host Member State either by establishing a branch or by providing services cross-border without one. The termination annex addresses the branch route under AIFMD Article 33 and UCITS Article 17. Ending a free-provision-of-services arrangement involves a different particular and a different notification.

Terminating one branch leaves the manager’s Luxembourg authorisation and its other passport activity intact. The Article 33(6) or Article 17(8) notice tells the supervisor a specific branch is closing, and nothing more.

Frequently Asked Questions

Which annex applies to my firm, the Article 33 one or the Article 17 one?

Match the annex to the authorisation under which the branch was opened. An alternative investment fund manager closing a management branch uses the Article 33 AIFMD annex. A UCITS management company authorised under Chapter 15 of the Law of 17 December 2010 uses the Article 17 UCITS annex. A firm holding both licences that ran a branch under each files the relevant annex for each.

How far ahead of the closure do I have to notify?

For a planned branch closure the directive sets a floor of one month before you implement the change, under AIFMD Article 33(6) and UCITS Article 17(8). That is a floor to plan backwards from, so more lead time is prudent where the host authority also has to be told.

Do I file with the CSSF, the host supervisor, or both?

It depends on the regime. AIFMD Article 33(6) has the AIFM notify its home authority only, so a Luxembourg AIFM files with the CSSF and the CSSF informs the host. UCITS Article 17(8) requires written notice to both the home and the host authority, so a Chapter 15 ManCo notifies the CSSF and the host supervisor directly.

Where do I submit the annex?

Through the CSSF eDesk portal, the channel the CSSF uses for European passport notifications. The termination annex is a DOCX form completed and lodged alongside the manager’s existing passport file.

Does the Version 1.1 update change what I owe?

The update refreshes the CSSF form. The substantive obligation, notice of a change of particulars ahead of a planned branch closure, comes from AIFMD Article 33(6) and UCITS Article 17(8) and did not change on 15 July 2026. File using the current Version 1.1 download; an older saved copy will be out of date.

Related Articles

• CSSF UCITS merger application forms – the domestic, outbound and cross-border merger forms that sit alongside the passport annexes.
• CSSF AIF and ELTIF marketing notification letter – the marketing-side filing, distinct from the branch route.
• AIFMD II Annex IV reporting changes – how the supervisory reporting return is evolving for AIFMs.
• CSSF IFM ancillary services notification – another eDesk notification investment fund managers file with the CSSF.
• CRD6 third-country branch authorisation – the inbound branch regime, for contrast with the outbound passport.

Key Takeaways

• Both branch termination annexes (Version 1.1 as of 15 July 2026, first published 16 February 2026) are DOCX forms filed through the CSSF eDesk portal.
• Match the annex to the authorisation: Article 33 of AIFMD for alternative investment fund managers, Article 17 of the UCITS Directive for Chapter 15 management companies.
• A branch closure falls under the change-notification procedure in AIFMD Article 33(6) or UCITS Article 17(8); planned closures require written notice at least one month before implementation.
• AIFMs notify the home authority (the CSSF) only; UCITS management companies notify both the CSSF and the host authority.
• The outbound branch termination annex covers this step alone; licence surrender and marketing de-notification each require separate filings.

Sources and References

• CSSF, “CSSF Annex – Termination of the operation of a branch under Article 33 of Directive 2011/61/EU (AIFMD)”, Version 1.1 (published 16 February 2026, updated 15 July 2026): cssf.lu
• CSSF, “CSSF Annex – Termination of the operation of a branch under Article 17 of Directive 2009/65/EC (UCITSD)”, Version 1.1 (published 16 February 2026, updated 15 July 2026): cssf.lu
• CSSF, UCITS management company European passport page (eDesk submission, Articles 17 and 18): cssf.lu
• CSSF, AIFM European passport page (Article 33 notification forms and eDesk submission): cssf.lu
• Directive 2011/61/EU (AIFMD), Article 33 (managing EU AIFs established in other Member States), EUR-Lex: eur-lex.europa.eu
• Directive 2009/65/EC (UCITS), Article 17 (establishment of a branch), EUR-Lex: eur-lex.europa.eu

Closing the branch cleanly

A branch closure looks like a small filing, and on eDesk it is. The risk sits in two details the annex does not spell out: the one-month advance notice a planned closure needs, and the difference between AIFMD and UCITS on who must receive it. Match the right annex to the right licence, file the current Version 1.1 form, and let the directive’s notice period set the date.

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.