CSSF Fund Notification Forms: Filing Under Circular 25/894

On 25 August 2026 the CSSF refreshed the CSSF fund notification forms that Luxembourg investment fund managers use to tell the regulator which non-authorised funds they run. The initial and update templates for UCITS and for AIFs, in both a with-compartments and a without-compartments version, now carry a 25 August 2026 revision date on the CSSF website. A form saved to a shared drive last year is no longer the current form.

These templates sit under Circular CSSF 25/894, published on 27 June 2025, which replaced the older Circular CSSF 15/612. The circular tells a Chapter 15 management company (ManCo15), an authorised alternative investment fund manager (AIFM) and a registered AIFM what information to submit to the CSSF for each fund they manage that the CSSF has not itself authorised. The circular establishes a live filing chain, and the form version you upload is part of it.

The practical exposure is small but real: filing on a superseded template, or treating the initial notification as the end of the obligation, creates a compliance gap. Three things carry the weight here, the current form version, the working-day deadlines in the circular, and the boundary with the separate cross-border passport notifications.

Related reading: CSSF AIFMD II passport notifications

What changed in the 25 August 2026 form refresh

The CSSF publishes seven templates for the Circular 25/894 process. Four are initial and update notification forms: an AIF form and a UCITS form, each in a version for funds with multiple compartments and a version for funds without compartments. Two are cease-of-management forms, one for AIFs and one for UCITS. The seventh is the registration form for an alternative investment fund manager. For a registered AIFM, the CSSF also requires an updated Registration form when the manager starts managing an additional AIF and when it terminates management of an AIF; if the termination concerns the last AIF managed, the manager must also ask the CSSF to remove it from the register of AIFMs. All four initial and update forms now show a 25 August 2026 update date, having first appeared on 18 July 2025.

The guideline treats the marked CSSF website templates as Excel or Word templates. Once completed, the relevant Excel or Word template must be exported to PDF-text format and uploaded through eDesk, with the correct document type selected when adding a document. Because the CSSF updates the forms published on its document pages, use the version currently published on the relevant CSSF page at the time of filing rather than relying on a stored copy.

Which funds the CSSF notification forms capture

The circular is about funds the CSSF does not authorise. Its scope covers European UCITS managed by Luxembourg ManCo15s and, for Luxembourg AIFMs within the circular’s scope, European AIFs, non-authorised AIFs established in Luxembourg and AIFs established in third countries. European and third-country AIFs may be authorised or non-authorised in their home country. For Luxembourg AIFs, the FAQ confirms that a Part II UCI, SIF or SICAR falls outside this notification population; RAIFs and other non-authorised Luxembourg AIFs can fall within it.

The common misreading runs the other way. A Luxembourg Part II fund, a SIF or a SICAR is authorised by and under the prudential supervision of the CSSF, so it does not belong in the 25/894 process at all. The circular is intended to give the CSSF a comprehensive and up-to-date view of funds managed by Luxembourg IFMs where existing information obligations do not always provide that view. An ELTIF label does not take a fund out of scope: a non-authorised Luxembourg AIF that is authorised as an ELTIF for at least one compartment must still be notified, and the information must be kept up to date for additions or changes of ELTIF. Marketing that same fund runs through a separate channel, the CSSF AIF and ELTIF marketing notification letter.

The dates that govern each filing

Section 5 of the circular sets the operative windows, and the CSSF spelled them out further in the version 2 FAQ of 3 October 2025. The calendar a reporting officer needs to hold:

• Fund already in existence when management starts: submit the information no later than 10 working days after the IFM starts managing the additional European UCITS or AIF. Where a European management-passport notification is also required, the CSSF says the Circular 25/894 notification should in principle be submitted first.
• Fund not yet established when management starts: the information is submitted no later than 10 working days after the fund is established.
• Service providers not final at launch: the CSSF expects potential providers to be indicated on the form; if one or more providers ultimately appointed differ from those notified, the IFM must update the form within 10 working days following signature of the agreement.
• An AIF placed into liquidation: inform the CSSF of the effective date within 10 working days of that date.
• Cease of management: submit the cease form at the time management stops, and at the latest 10 working days after the event.

Ten working days applies to specified events, including the initial notification deadline, the post-establishment case addressed in the FAQ, a differing service-provider appointment, liquidation of an AIF and cessation of management. Other substantial changes to information or documents submitted under the circular must be notified without delay.

Why the initial form is never the last form

The word “update” in the form title carries weight. The circular treats the initial notification as the opening entry in a record the IFM then keeps current for the life of the mandate. The guideline identifies update submissions for adding a new sub-fund, changing the depositary or central administrator, liquidation or merger of a sub-fund or the whole AIF, and other changes. The FAQ separately confirms that a change of AIFM also requires notification. A status change from an authorised AIF to a non-authorised AIF triggers a notification even when the AIFM stays the same. This record sits alongside the manager’s other standing duties, such as the CSSF notification of ancillary services to third parties.

FAQ version 2 states that, for AIFs already notified when the FAQ was issued, automatic resubmission of the then-new forms was not necessary; those forms and the new information they contained had to be submitted when changes occurred. The same FAQ states that foreign UCITS already managed by a Luxembourg ManCo15 before Circular 25/894 took effect were subject to retroactive notification. That FAQ was published on 3 October 2025, before the 25 August 2026 form refresh, so it does not establish whether the 2026 refresh itself creates any separate re-filing requirement.

Keep it separate from the AIFMD II passport notifications

Two Luxembourg fund-notification workflows moved within weeks of each other in 2026, each serving a distinct purpose. Circular 25/894 records which non-authorised funds an IFM manages; the cross-border management and marketing passport notifications, updated on the CSSF templates that became mandatory on 31 July 2026 after the Law of 3 March 2026 transposed AIFMD II, record where an IFM passports its activity across the European Economic Area.

They interact in sequence rather than substituting for one another. The 25/894 FAQ states that, in principle, the relevant fund notification under the circular should be submitted before the freedom-to-provide-services or branch notification for managing it. Where a European management-passport notification is required, the manager may therefore have both a Circular 25/894 notification and a separate passport notification. The 25/894 FAQ says that, in principle, the Circular 25/894 notification should be submitted first.

Frequently Asked Questions

Does an ELTIF authorisation take a Luxembourg AIF out of the 25/894 process?

No. A non-authorised Luxembourg AIF that is authorised as an ELTIF for at least one of its compartments must still be notified under the circular, and the AIFM has to keep the information current, including any addition or change of ELTIF. The CSSF requires the annexes relating to an ELTIF change to be submitted through the dedicated eDesk procedure for notifications under the circular.

Can I notify a fund that is still being set up?

Only funds that already exist can be notified under the circular. Where an AIFM begins managing an AIF that is still being set up, the management itself may be notified under the freedom to provide services or via a branch notification under Article 33 of the AIFMD, but the AIF has to be notified under Circular 25/894 once it is established.

How are the completed forms submitted to the CSSF?

Through eDesk. The Excel or Word template is completed, exported to PDF-text format, and uploaded under the matching request type. Financial reports for the funds concerned, such as the annual and semi-annual reports, are submitted through the relevant eDesk procedure, the same channel used for the forms.

Related Articles

• CSSF AIFMD II Passport Notifications: How the cross-border management and marketing passport templates changed after the AIFMD II transposition.
• CSSF IFM Ancillary Services Notification: What an investment fund manager must notify when it provides services to third parties.
• CSSF AIF and ELTIF Marketing Notification Letter: The marketing notification route that sits alongside the fund-population filing.
• CSSF Branch Termination Annex for AIFMD and UCITS: The de-notification annex used when a branch or cross-border activity ends.
• CSSF Reporting Calendar Q3 2026: Where fund and prudential reporting deadlines fall for Luxembourg entities this quarter.

Key Takeaways

• Use the 25 August 2026 versions of the four initial/update forms. For cease-of-management filings, download the current CSSF form at filing; the AIF and UCITS cease-form pages are currently dated 17 December 2025.
• Circular 25/894 captures foreign UCITS, foreign AIFs and non-authorised Luxembourg AIFs, meaning those not set up as a Part II UCI, SIF or SICAR.
• An ELTIF authorisation does not remove a non-authorised Luxembourg AIF from the circular.
• In principle, the relevant fund notification should be submitted before the freedom-to-provide-services or branch management notification; where the fund has not yet been established when management begins, it must be notified no later than 10 working days after establishment.
• A service-provider change against what was notified is an update due within 10 working days of the agreement signature.
• Liquidation of an AIF and cease of management are each notified within 10 working days.
• The 25/894 notification is not the AIFMD II cross-border passport notification, whose updated templates became mandatory on 31 July 2026.

Sources and References

• Circular CSSF 25/894, Information to be submitted to the CSSF in relation to investment funds non-authorised by the CSSF (27 June 2025): cssf.lu
• FAQ, Circular CSSF 25/894, Version 2 (3 October 2025): cssf.lu (PDF)
• Circular CSSF 25/894, Guideline for documents to be submitted, Version 1 (26 June 2025): cssf.lu (PDF)
• Initial/update form UCITS with multiple compartments (updated 25 August 2026): cssf.lu
• Initial/update form AIF without compartments (updated 25 August 2026): cssf.lu
• Registration of an alternative investment fund manager and subsequent amendments: cssf.lu
• CSSF communication on management notifications and de-notifications with a European passport, changes introduced by AIFMD II (30 July 2026): cssf.lu
• Law of 17 December 2010 relating to undertakings for collective investment: cssf.lu
• Law of 12 July 2013 on alternative investment fund managers: cssf.lu

Before your next fund onboarding

Two checks close the loop. Confirm that the initial/update form you are about to upload is the current 25 August 2026 version, and confirm that every fund already in your 25/894 record reflects its current notified information. Substantial changes must be notified without delay; the FAQ’s 10-working-day deadline for service providers applies where a provider appointed after launch differs from the provider previously notified. The next fund you take on, or the next one you hand back, is the moment the current form and the current record both have to be in place.

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.