LINARI LAW

CSSF Circular 25/901: reinforced guidance for Luxembourg funds — and a benchmark for RAIFs

In force since 19 December 2025, Circular 25/901 issued by the CSSF consolidates and modernises the prudential expectations for SIFs, SICARs and Part II UCIs (including compartments). It replaces several legacy texts with a single, clearer reference and aligns supervisory practice with today’s market realities.

The CSSF also published a companion “Compilation of key concepts and terms” to standardise the vocabulary used for alternative funds (investment policy, strategies/asset classes, methods and subscription/redemption models) and to make supervisory exchanges more efficient.

In practice, sponsors will feel the impact in several areas. Risk-spreading is framed through investor-calibrated concentration thresholds: a 25% baseline cap towards one entity/person for products marketed to unsophisticated retail investors; generally, 50% for well-informed/professional investors, with infrastructure strategies tolerated up to 70%. A look-through approach is expected when intermediary vehicles are used. Borrowing is clearer; retail investors should, in principle, keep borrowing for investment purposes within a 70% baseline, while professional or Well-informed investors, their limits are caped at the discretion of the fund. The Circular formalises ramp-up guidance (often up to one year for liquid strategies and up to four years for illiquid/private strategies, with potential limited extensions).

Although RAIFs are not directly in scope, the Circular is expected to drive RAIF market standards. Executive analysis anticipates that RAIF Offering Memorandums will mirror the Circular’s disclosure depth (limit calculation basis, SPV look-through, maximum borrowing and liquidity tools); that temporary bridge financing fully covered by commitments is generally not treated as “borrowing”; and that for RAIF–SICAR-like strategies the Circular’s risk-capital logic (value-creation, specific risk; ABS, CDOs and hedge funds generally not eligible) will guide eligibility assessments. This reinforces Luxembourg’s offering to investors, clarity where investors demand it, flexibility where strategies need it, and provides a stable, well-supervised platform to raise and deploy capital confidently.

Please feel free to contact any member of our team directly to discuss your upcoming projects and to receive further details on the scope of our investment funds services.

 

 

Photo – Rosc Art

www.rosc-art.com

PREVIOUS NEXT

Related posts

Browse All

Latest proposals to amend working hours

Luxembourg is considering reforms to working time arrangements, including four-day working weeks, reduced weekly rest periods, additional breaks and greater flexibility for part-time employees. The proposals have sparked disagreement between employers and trade unions, particularly over whether small businesses should be exempt from the requirement for collective bargaining agreements. Discussions…

A new age for the European securitization market? The Council and the Parliament’s political agreement on the Securitization Regulation

The European Council and Parliament have reached a political agreement on proposed reforms to the EU Securitization Regulation, aiming to simplify the securitization framework and encourage investment. Key measures include more risk-sensitive bank capital requirements, the introduction of resilient securitizations, enhanced STS supervision and increased investment limits for UCITS. These…

Luxembourg retains its AAA rating: Strong fundamentals and a stable outlook

On 23 October 2026, Fitch Ratings and Morningstar DBRS reaffirmed Luxembourg’s AAA rating with a stable outlook, so the Grand Duchy now holds the highest grade from all five major agencies. Fitch highlights public debt of only 26.0% of GDP at end-2025, which is the second-lowest among AAA-rated peers, along…

CSSF FAQ regarding the use of DLT in Tokenised Funds

On 2 October 2026, the CSSF published an FAQ on how Distributed Ledger Technology (DLT) may be used to issue, hold and transfer units or shares of Luxembourg investment funds. UCI administrators acting as registrar agent may keep the register of registered units on DLT, and for dematerialised units they…

IFLR1000 2027 – Renewed recognition of our expertise

Linari Law Firm has been recognised in the IFLR1000 2027 edition, marking its eleventh consecutive year in this leading guide to financial and corporate law firms. The firm is rated in four practice areas: Investment Funds, Banking, Capital Markets and M&A. This consistent recognition reflects the firm’s approach of close…

Team Building in Mallorca

From 2 to 5 October, the Linari Law Firm team travelled to Port Adriano for a team building weekend in Mallorca, joined by their partners. The programme combined wine tastings, harbour walks and long dinners exploring Mallorcan cuisine. As a boutique law firm, Linari sees its close-knit relationships as its…
Browse All

A LEGACY OF LAW. A FUTURE OF INNOVATION.
25 years of legal excellence – the journey continues.

Contact Info

+352 27 11 60 10

UP