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

Trusts and foundations in a company’s ownership chain: LBR clarifies who must be registered with the RBE

Circular LBR 26/01 clarifies how beneficial owners should be identified for Luxembourg companies held through trusts or foundations. According to LBR, the beneficial owners of the underlying trust or foundation should be reported to the RBE by applying the specific rules under Article 1(7)(b) and (c) of the 2004 AML…

Career Opportunity: Avocat à la Cour (Luxembourg)  Associate – Commercial and Civil litigation

Career Opportunity: Avocat à la Cour (Luxembourg) Associate – Commercial and Civil litigation

Career Opportunity: Avocat à la Cour (Luxembourg)  Associate – Corporate Law and/or Banking and Finance

Career Opportunity: Avocat à la Cour (Luxembourg)  Associate – Corporate Law and/or Banking and Finance Location: Strassen, LuxembourgLanguages: English and French (mandatory)   About Linari Law Firm – Linari-Law Firm is a recognized boutique law firm with a 25-year track record of advising a diverse clientele, from multinational corporations to…

Enjoy Your Beautiful Summer!

As summer is in full swing, we would like to wish you the most peaceful, memorable, and joyful summer ever. This summer break is the perfect time to relax and spend quality time with your loved ones. While we’re here to assist and help you, we unfortunately will be pausing…

Modernisation of SCS /SCSp Toolbox — Compartmentalisation

Bill 8814 proposes a major enhancement to Luxembourg’s alternative investment fund toolbox by allowing certain SCS and SCSp AIFs to operate as multi-compartment structures. The reform would provide greater flexibility for parallel funds and structures inspired by foreign vehicles such as US Series LLCs. Each compartment would generally benefit from…

Luxembourg Introduces New Bill to Further Modernise its Securitisation Framework

Luxembourg continues to strengthen its position as a leading securitisation hub with the introduction of Bill No. 8761. The proposed reform modernises the securitisation framework by increasing financing flexibility, expanding active management possibilities, and clarifying key legal rules. The amendments aim to provide greater certainty for sponsors, investors, and market…
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