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AIFMD II Reporting to CSSF: Everything You Need to Know

Commission de Surveillance du Secteur Financier — Luxembourg

Contact & Filing Portal

Website: https://www.cssf.lu
Filing Portal: CSSF eFile
Email: direction@cssf.lu
Phone: +352 26 251-1

Transposition Status

Transposed

Luxembourg transposed AIFMD II via amendments to the 2013 Law on Alternative Investment Fund Managers. The CSSF published updated circular letters (CSSF Circulars) with detailed implementation guidance in Q4 2025.

Filing Deadlines

Quarterly

30 days after quarter-end

For AIFMs managing >€1bn AuM or funds employing substantial leverage

Semi-Annual

45 days after period-end

For mid-sized AIFMs with €500m–€1bn AuM

Annual

30 days after year-end

For registered/small AIFMs below de minimis thresholds

CSSF-Specific Quirks & Deviations

S-type and O-type fund codes

CSSF uses its own fund classification system (S-type for UCITS-like structures, O-type for alternative) that must be mapped alongside ESMA fund type codes in every filing.

eFile portal technical requirements

The CSSF eFile system requires filings in a specific ZIP structure with a manifest XML file. The portal has strict file size limits (50MB per submission) and requires digital certificates for authentication.

Mandatory quarterly investor reporting

Beyond Annex IV, CSSF requires supplementary quarterly investor composition reports breaking down investors by domicile, type (professional/retail), and investment size bands.

Cross-border passporting notifications

For AIFMs using Luxembourg as a passporting hub, CSSF requires additional notification filings within 10 business days of any new marketing arrangement in another EU member state.

CSSF-specific risk metrics

CSSF requires additional liquidity stress test reporting beyond the ESMA minimum, including a proprietary 5-scenario liquidity simulation that must be recalculated monthly for leveraged funds.

Strict amendment deadlines

If a filing error is discovered, CSSF requires corrective amendments within 5 business days — significantly shorter than most NCAs.

How Caelith Helps with CSSF

✓Generates CSSF-compliant ZIP archives with manifest files automatically
✓Maps CSSF S-type/O-type codes alongside ESMA fund types
✓Produces supplementary investor composition reports
✓Tracks the strict 5-day amendment correction window
✓Automates cross-border passporting notification filings

Frequently Asked Questions

How does CSSF eFile work for AIFMD II reporting?▾

CSSF eFile requires submissions as a ZIP archive containing the Annex IV XML file and a manifest XML. Digital certificates are required for authentication, and file sizes are limited to 50MB per submission.

What extra reporting does CSSF require beyond Annex IV?▾

CSSF requires supplementary quarterly investor composition reports, additional liquidity stress testing with 5-scenario simulations, and cross-border marketing notifications.

How quickly must filing errors be corrected with CSSF?▾

CSSF requires corrective amendments within 5 business days of discovering an error — one of the shortest correction windows among EU NCAs.

Does Luxembourg have special fund codes for AIFMD II?▾

Yes, CSSF uses its own S-type (UCITS-like) and O-type (alternative) fund classification system that must be included alongside ESMA fund type codes in every filing.

Related Resources

All NCA Profiles

Compare requirements across countries

Luxembourg Deadlines

Filing calendar for CSSF

AIFMD II Glossary

Key terms & definitions

What is an NCA?

Glossary definition

Annex IV XML Explained

Practical guide to the ESMA schema

Caelith vs anevis

Compare reporting solutions

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