CSSF LMT Activation Module: Notifying a Redemptions-Only Suspension

On 18 September 2026 the CSSF told the Luxembourg investment fund industry that, as from 21 September 2026, the activation and deactivation of a suspension of redemptions only must be notified through the eDesk “LMT activation” module. The change reaches Luxembourg-domiciled undertakings for collective investment governed by the Law of 17 December 2010, specialised investment funds governed by the Law of 13 February 2007, and investment companies in risk capital governed by the Law of 15 June 2004. It gives fund managers a matter of days to route a familiar national-law event through the CSSF LMT activation module, a channel that was built for something narrower.

The CSSF LMT activation module was introduced earlier in 2026 to receive notifications about the harmonised liquidity management tools that Directive (EU) 2024/927 added to the AIFMD and the UCITS Directive. A suspension of redemptions on its own is not one of those harmonised tools. The CSSF is folding it into the same module for administrative convenience, and the communique is careful to say so. That distinction, between a harmonised liquidity management tool and a national-law measure that merely shares a notification channel, is the point a reporting officer has to get right before touching eDesk.

Nothing here changes the substance of when a fund may suspend redemptions; the sectoral laws and the fund documents still govern that. What changes on 21 September 2026 is where the notification goes.

Related reading: AIFMD II Liquidity Management Tools

The dates that decide what changes on 21 September 2026

The communique of 18 September 2026 is short, but it sits on top of a year of framework dates that determine what the module is for and who must use it. The calendar a Luxembourg fund team should keep in front of it looks like this:

• 15 April 2025: ESMA publishes its Final Report on the Guidelines on liquidity management tools of UCITS and open-ended AIFs (ESMA34-1985693317-1160).
• November 2025: the European Commission adopts the delegated regulations specifying the characteristics of liquidity management tools under the AIFMD and the UCITS Directive.
• 18 December 2025: ESMA publishes its report on the amended Guidelines on LMTs, aligning them with the adopted technical standards (ESMA34-671404336-1363).
• 3 March 2026: the Luxembourg Law transposing Directive (EU) 2024/927 is adopted (the “2026 Law”).
• 12 March 2026: ESMA publishes the final Guidelines on liquidity management tools of UCITS and open-ended AIFs (ESMA34-671404336-1364).
• 18 March 2026: the CSSF communique detailing the “LMT selection” module.
• 10 April 2026: the CSSF communique detailing the “LMT activation” module for activation and deactivation notifications.
• 16 April 2026: the transposition date; existing sub-funds must comply with the LMT eDesk requirements from this date, and new sub-funds from the date of their establishment.
• 18 September 2026: the CSSF communique extending the “LMT activation” module to a suspension of redemptions only.
• 21 September 2026: activation and deactivation of a suspension of redemptions only must be notified through the eDesk “LMT activation” module.
• 16 April 2027: the end of the one-year transitional period for funds constituted before 16 April 2026 to comply with the technical standards.

Two of those dates are already behind Luxembourg managers. The eDesk obligation for the harmonised tools has applied since 16 April 2026, and the module itself has been live since April. The 21 September 2026 date adds a new category of event to a channel that already exists.

Why a redemptions-only suspension is not a liquidity management tool

The harmonised list that Directive (EU) 2024/927 inserted into Annex V of the AIFMD and Annex IIA of the UCITS Directive opens with a single suspension tool: the suspension of subscriptions, repurchases and redemptions. A manager that halts redemptions but leaves subscriptions open is instead taking a different, narrower measure under the national-law provisions of the sectoral product laws, outside the harmonised LMT regime.

The CSSF communique states the consequence plainly: the suspension of redemptions only, without suspension of subscriptions, does not qualify as a liquidity management tool under the 2026 Law. It is integrated into the “LMT activation” module to simplify notification procedures for market participants, not because the measure has been reclassified as an LMT. The label on the module is wider than the legal category behind the filing.

This matters beyond terminology. The 2026 Law obligations tied to the harmonised tools include a general duty to select at least two tools from points 2 to 8 and to reflect the selected tools in the fund documents, subject to the derogation permitting an AIF or UCITS authorised as a money market fund under Regulation (EU) 2017/1131 to select only one such tool. A national-law suspension of redemptions does not trigger those selection obligations by itself. Reading the eDesk module name as evidence that a redemptions-only suspension is now a harmonised LMT would invert what the CSSF has said.

Which Luxembourg funds the eDesk extension reaches

The extension is drawn along product-law lines. It applies to Luxembourg-domiciled funds subject to the 2010 Law relating to UCIs, to specialised investment funds under the 2007 Law, and to investment companies in risk capital under the 2004 Law. Those are the vehicles whose national-law framework allows a suspension of redemptions, and those are the vehicles the CSSF names.

The extension does not create a new reason to suspend, and it does not change the conditions under which a suspension is permitted. Those conditions continue to live in the sectoral laws and in each fund’s constitutional documents and prospectus. The communique aligns with the CSSF’s stated aim of streamlining administrative processes, which means the substance of the decision to suspend is untouched and only the notification route is being consolidated.

A team that manages a mixed range should map its vehicles against these three laws before 21 September 2026, because the module is the destination for a redemptions-only suspension across all three product types from that date.

How the CSSF LMT activation module now handles a redemptions-only suspension

From 21 September 2026, both the activation and the deactivation of a suspension of redemptions only are notified through the eDesk “LMT activation” module. The module already captured notifications of full suspensions, side-pocket activations and deactivations, and activations or deactivations of tools at points 2 to 8 where these occur other than in the ordinary course of business as envisaged in the fund rules or instruments of incorporation; the communique adds the redemptions-only case.

What does not move into eDesk is the supporting file. The CSSF is explicit that the administrative requirements, including the submission of supporting documentation, remain unchanged and must continue to be submitted through the usual communication channels. The module records the activation or deactivation event; it does not replace the correspondence, approvals, or documentation a suspension would otherwise generate. A manager that treats the eDesk entry as the whole filing would leave the documentary obligations unmet.

Operationally, that splits the workflow. The reporting or transfer-agency function books the activation and later the deactivation in the module, while the documentation continues along the established channel to the CSSF. Confirming who owns each half of that split, and that both halves fire for the same event, is the practical step to lock down before the module goes live for redemptions-only cases.

The separate reminder for Part II UCIs and certain SIFs and SICARs

The communique carries a reminder aimed at a specific population. Luxembourg-domiciled funds subject to Part II of the 2010 Law that are not managed by a Luxembourg-domiciled authorised AIFM must also notify the CSSF, through the “LMT activation” module, of the activation or deactivation of suspensions of subscriptions, repurchases and redemptions, as well as the creation of side pockets previously approved by the CSSF, as required under the respective sectoral laws. The same applies to funds under the 2007 Law and the 2004 Law that do not qualify as AIFs or are not managed by a Luxembourg-domiciled authorised AIFM.

This is a broader notification set than the redemptions-only case that headlines the communique. It covers the full suspension tool and the creation of a side pocket, and it is grounded in the sectoral laws rather than in the harmonised LMT obligations that apply to authorised AIFMs. Side pockets sit at point 9 of the harmonised list. Here, the CSSF is pointing to a notification duty under the sectoral laws for the specified Part II UCI, SIF and SICAR populations, including funds that do not qualify as AIFs and funds that are not managed by a Luxembourg-domiciled authorised AIFM.

For Part II UCIs, the relevant test is whether the fund is managed by a Luxembourg-domiciled authorised AIFM. For SIFs under the 2007 Law and SICARs under the 2004 Law, the reminder applies where the fund does not qualify as an AIF or is not managed by a Luxembourg-domiciled authorised AIFM.

Where the module sits in the 2026 Law’s selection-and-activation architecture

The eDesk procedure has two connected modules, and the redemptions-only notification lives in the second of them. The CSSF communique of 18 March 2026 described the “LMT selection” module, and the communique of 10 April 2026 described the “LMT activation” module for notifications of activation and deactivation. Selection is the up-front communication of the chosen tools and related information; the activation module is used for the activation and deactivation notification events specified by the CSSF, including full suspensions, side pockets and non-ordinary-course activations or deactivations of tools at points 2 to 8.

Under the 2026 Law, which transposes Directive (EU) 2024/927, managers of open-ended AIFs and UCITS must generally select at least two liquidity management tools from points 2 to 8 of the harmonised list and reflect the selected tools in the fund rules or instruments of incorporation; an AIF or UCITS authorised as a money market fund under Regulation (EU) 2017/1131 may select only one such tool. Article 16(2b) of the AIFMD and Article 18a of the UCITS Directive frame that selection duty, drawing the selected tools from points 2 to 8 of the harmonised list. The suspension of subscriptions, repurchases and redemptions at point 1, and side pockets at point 9, remain available to every manager for exceptional circumstances without counting toward the minimum of two. Our guide to the AIFMD II liquidity management tools regime walks through the full selection and calibration duties.

The CSSF has reiterated that existing sub-funds, as from 16 April 2026, and new sub-funds from the date of their establishment, must comply with the LMT eDesk requirements. However, a deactivation of an LMT that was activated before 16 April 2026 must not be notified through the “LMT activation” module and must instead follow the usual CSSF procedure. The redemptions-only extension slots into that established plumbing: a national-law event travelling through the activation module that the 2026 Law framework created for the harmonised tools. For funds that also file periodic AIFMD supervisory data, this communique addresses the LMT eDesk procedure and does not set out changes to periodic AIFMD reporting.

How this maps to the ESMA LMT standards

The Luxembourg framework rests on a European base that reporting teams should keep distinct from the CSSF’s notification plumbing. ESMA published its Final Report on the Guidelines on liquidity management tools of UCITS and open-ended AIFs on 15 April 2025. After the European Commission adopted the delegated regulations specifying the characteristics of those tools on 17 November 2025, ESMA published its report on the amended Guidelines on 18 December 2025 and the final Guidelines, ESMA34-671404336-1364, on 12 March 2026.

Those standards apply from 16 April 2026, with a one-year transitional period to 16 April 2027 for funds constituted before that date. A fund that manages its liquidity risk against the ESMA Guidelines is doing something different from filing an eDesk notification. The calibration of a redemption gate or a swing-pricing factor answers to the technical standards and the Guidelines; the eDesk entry simply records that an activation or deactivation happened. Confusing the two would mean treating a notification channel as if it discharged a calibration duty.

For funds holding less liquid or illiquid assets, the CSSF’s illiquid asset valuation thematic review addresses valuation policies, procedures and controls. Separately, the ESMA common supervisory action on the risk management function examines governance and organisation of the risk management function, risk identification, measurement and monitoring, and reporting to senior management and governing bodies.

Frequently Asked Questions

If a fund suspends both subscriptions and redemptions, does it still notify through the activation module?

Yes, but on a different legal footing. A suspension of subscriptions, repurchases and redemptions is the harmonised liquidity management tool at point 1 of the Annex V and Annex IIA list, and its activation and deactivation are already notified through the “LMT activation” module. The 21 September 2026 change adds the narrower redemptions-only case, which the 2026 Law treats as a national-law measure outside the harmonised list.

Does routing the notification through eDesk remove the need to send supporting documentation?

No. The CSSF states that administrative requirements, including the submission of supporting documentation, remain unchanged and must continue through the usual communication channels. The module captures the activation or deactivation event; the documentary file follows its established route.

What happens if a fund’s manager is not a Luxembourg-domiciled authorised AIFM?

For Part II UCIs under the 2010 Law that are not managed by a Luxembourg-domiciled authorised AIFM, and for 2007 Law and 2004 Law funds that do not qualify as AIFs or are not so managed, the communique reminds managers to notify, through the module, the activation or deactivation of suspensions of subscriptions, repurchases and redemptions and the creation of side pockets previously approved by the CSSF, as required under the respective sectoral laws.

Does the extension change when a fund is allowed to suspend redemptions?

No. The conditions for a suspension continue to sit in the sectoral product laws and in each fund’s constitutional documents and prospectus. The communique consolidates the notification route; it does not alter the substantive grounds for suspending.

Is a redemptions-only suspension one of the two tools a manager must select under the 2026 Law?

No. The general minimum of two tools is drawn from points 2 to 8 of the harmonised list under Article 16(2b) of the AIFMD and Article 18a of the UCITS Directive, subject to the derogation allowing an AIF or UCITS authorised as a money market fund under Regulation (EU) 2017/1131 to select only one such tool. A suspension is point 1 and side pockets are point 9; both are available for exceptional circumstances but do not count toward the minimum, and a redemptions-only suspension is not a harmonised tool at all.

Do closed-ended vehicles need to use the module for this?

The extension is framed around the ability to suspend redemptions under the 2010, 2007 and 2004 Laws, which is an open-ended feature. A vehicle without redemption rights would not activate a suspension of redemptions, so the module event would not arise for it; the decisive test is whether the fund can and does suspend redemptions under its governing law and documents.

Does the communique set a deadline for making the notification after a suspension is decided?

The communique fixes 21 September 2026 as the date from which the module becomes the channel, and it does not restate a separate timing rule for the notification itself. The timing and content of the underlying notification continue to follow the sectoral laws and the CSSF’s existing expectations, which is why the documentation duties are described as unchanged.

Related Articles

• AIFMD II Liquidity Management Tools: how the harmonised tools, selection duty and calibration standards work under Directive (EU) 2024/927.
• CSSF Illiquid Asset Valuation Thematic Review: the supervisory expectations on valuing hard-to-price assets that sit behind a suspension decision.
• CSSF AIFMD II Passport Notifications: how the CSSF has reshaped cross-border notification workflows under the AIFMD review.
• AIFMD II Annex IV Reporting Changes: the periodic AIFM reporting updates that run alongside the LMT regime.
• CSSF UCITS and AIF Notification Forms Circular 25-894: the notification-form framework Luxembourg managers use for UCITS and AIFs.
• ESMA Risk Management Function CSA for Fund Managers: the governance expectations examined in ESMA’s common supervisory action.

Key Takeaways

• From 21 September 2026, activation and deactivation of a suspension of redemptions only are notified through the CSSF eDesk “LMT activation” module for 2010 Law UCIs, 2007 Law SIFs and 2004 Law SICARs.
• A suspension of redemptions only is a national-law measure folded into the module to streamline notification; the 2026 Law treats it as sitting outside the harmonised liquidity management tool list.
• Supporting documentation and the other administrative requirements remain unchanged and continue through the usual CSSF communication channels, and are not routed through eDesk.
• Part II UCIs not managed by a Luxembourg-domiciled authorised AIFM, and 2007 Law SIFs or 2004 Law SICARs that do not qualify as AIFs or are not managed by a Luxembourg-domiciled authorised AIFM, must also notify through the module full suspensions and the creation of previously approved side pockets under the sectoral laws.
• The harmonised framework generally requires selection of at least two tools from points 2 to 8, while an AIF or UCITS authorised as a money market fund under Regulation (EU) 2017/1131 may select only one; suspension (point 1) and side pockets (point 9) remain available for exceptional circumstances and do not count toward that selection requirement.
• Existing sub-funds have been subject to the LMT eDesk requirements since 16 April 2026, and new sub-funds from their establishment date; however, deactivations of LMTs that were activated before 16 April 2026 must follow the usual CSSF procedure rather than the “LMT activation” module.
• The ESMA Guidelines and the Commission’s technical standards on LMT characteristics apply from 16 April 2026, with a transitional period to 16 April 2027 for funds constituted before that date.

Sources and References

• CSSF, Communication to the investment fund industry regarding the requirement to notify the “suspension of redemption (only)” in the “LMT activation” module related to liquidity management requirements, 18 September 2026: cssf.lu.
• Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024 amending Directives 2011/61/EU and 2009/65/EU (AIFMD and UCITS review): eur-lex.europa.eu.
• ESMA, Final Report on the Guidelines on liquidity management tools of UCITS and open-ended AIFs (ESMA34-1985693317-1160), 15 April 2025: esma.europa.eu.
• ESMA, Report on amended guidelines on LMTs of UCITS and open-ended AIFs (ESMA34-671404336-1363), 18 December 2025: esma.europa.eu.
• ESMA, Final Guidelines on liquidity management tools of UCITS and open-ended AIFs (ESMA34-671404336-1364), 12 March 2026: esma.europa.eu.
• Commission Delegated Regulation (EU) 2026/465: eur-lex.europa.eu; Commission Delegated Regulation (EU) 2026/466: eur-lex.europa.eu.
• CSSF Communiqué of 18 March 2026 on the “LMT selection” module: cssf.lu; and CSSF Communiqué of 10 April 2026 on the “LMT activation” module (URL not available; as referenced in the 18 September 2026 CSSF communication).
• Luxembourg Law of 3 March 2026 transposing Directive (EU) 2024/927 (the “2026 Law”), as referenced in the CSSF communication of 18 September 2026.

What to confirm in eDesk before 21 September

The work between now and 21 September 2026 is mostly mapping. A Luxembourg manager should confirm which of its vehicles fall under the 2010, 2007 and 2004 Laws, decide who books the activation and deactivation of a redemptions-only suspension in the “LMT activation” module, and confirm that the supporting documentation still routes to the CSSF through the usual channel. For any Part II UCI not managed by a Luxembourg-domiciled authorised AIFM, and any SIF or SICAR that does not qualify as an AIF or is not managed by a Luxembourg-domiciled authorised AIFM, the same check extends to full suspensions and to side pockets previously approved by the CSSF. Once those owners and routes are fixed, the next redemptions-only suspension is a two-part filing: the event in eDesk, the file through the established channel.

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.