Circular 25/901: A Substantial Modernisation of Luxembourg Alternative Investments Funds Rules

On 19 December 2025, the Luxembourg supervisory authority Commission de Surveillance du Secteur Financier (CSSF) issued the Circular 25/901 relating to specialised investment funds (SIF), investment companies in risk capital (SICAR) and undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCI).

The Circular provides a single framework for alternative investment funds (AIFs) which covers investment restrictions (including simplifications and less restrictive thresholds for investments made by AIFs), borrowing, portfolio management techniques, risk capital criteria and transparency/disclosure obligations for the above-mentioned fund vehicles and replaces several long-standing CSSF circulars. The Circular introduces consistent investment rules and transparency, provides flexibility depending on the investor type and strengthens Luxembourg’s position as competitive fund domicile.

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