Financial Services

Changes in Statistical Data Collection for Investment Funds

Vaida Gončiauskaitė
By:
Vaida Gončiauskaitė
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The Banque Centrale du Luxembourg (BCL), in cooperation with the Commission de Surveillance du Secteur Financier (CSSF), are aligning statistical data collection for Investment Funds with the updated ECB Regulation (EU) 2024/1988 adopted on 27 June 2024.
Contents

The modifications aim to:

  • Ensure comprehensive statistics for the European Central Bank (ECB);
  • Minimise reporting burdens on Luxembourg-based investment funds;
  • Maintain data consistency between statistical and supervisory reporting;
  • Support financial stability and prudential supervision.

This circular BCL 2024/245 / CSSF 24/866 replaces and repeals previous regulations, including BCL 2014/237, CSSF 14/588, IML 97/136, and CSSF 08/376, CSSF 07/310, as amended by CSSF 08/348.

 

Entities in Scope

The modifications apply to the following types of investment funds:

  • Undertakings for Collective Investment in Transferable Securities (UCITS)
  • Undertakings for Collective Investment (UCIs) - Part II funds
  • Specialised Investment Funds (SIFs)
  • Investment Companies in Risk Capital (SICARs)
  • Alternative Investment Funds (AIFs) not authorised by the CSSF, including:
    • Reserved Alternative Investment Funds (RAIFs)
    • AIFs managed by a Luxembourg or foreign Alternative Investment Fund Manager (AIFM)

 

Key Modifications to Reporting

  • Monthly & Quarterly Balance Sheet Reporting:
    • All investment funds will have to submit monthly reports, except the non-UCITS funds with infrequent asset valuation;
    • Non-UCITS investment funds will have to submit quarterly reports.
  • Additional Data Points:
    • New items added to the monthly and quarterly balance sheet reports (S1.3 and S2.13), to Security-by-security reports (TPT), and to monthly financial information reporting (U.1.1);
    • New quarterly reporting for alternative investment funds (AIFs) not authorised by CSSF (S2.20);
    • New report to capture data on countries of marketing of investment funds' shares/units (S4.4).
  • Discontinuation of Reports:
    • Reports O4.1, O4.2, and K3.1 will be discontinued from December 2025.

 

Observe the deadlines

The new or updated reports must be submitted for the first time for the reference period of December 2025, no later than:

  • For Money Market Funds (MMFs):
    • 15 January 2026 – S2.13 and TPT
    • 8 April 2026 – S4.4
  • For Non-MMF Investment Funds:
    • 30 January 2026 – S1.6, S1.3 or S2.13 (depending on the type), and TPT
    • 8 April 2026 – S4.4
  • For AIFs non-regulated by the CSSF (NAFs):
    • 30 January 2026 – S1.6, S1.3 or S2.13 (depending on the type), TPT, and S2.20
    • 8 April 2026 – S4.4

Small NAFs with total assets below EUR 300 million (combining all sub-funds) may be exempted from all periodical reports. Funds seeking exemption must send their annual balance sheets within 15 days after their certification.

 

How we can help

This new circular modernises Luxembourg’s statistical data collection framework and aligns with the ECB regulations while keeping an eye on the administrative burden imposed on fund managers.

We recognise that these changes may have a significant impact on your daily processes. However, we are here to support you every step of the way, offering guidance and assistance to facilitate a smooth transition to the new requirements.

Contact

Our designated team is available to provide further clarification, develop detailed compliance timetables, and assist you in managing the transition to the updated data collection framework. If you need any support in analysing or implementing these new processes, please do not hesitate to reach out to Vaida Gončiauskaitė, Partner, Financial Services.