CSSF supervisory fees set to rise
The government has published a draft Grand-Ducal regulation that would replace the December 2022 fee scale, in order to bring supervisory fees into line with the CSSF’s rising costs. Most fees would go up by around 22%, but the increase is not the same for everyone and reaches up to 150% in a few cases. The main reason is higher costs.
The draft keeps one key principle from the current system: each type of supervised entity pays for the cost of its own supervision.
For banks, the increase is broadly around 22% and depends on the size of the balance sheet. The largest banks; those with a balance sheet above €2.5bn, would see their annual fee go up by 22.5%. Banking groups would be affected more: the surcharge for consolidated supervision would rise by 30.8%, in addition to higher fees for each subsidiary.
Setting up a fund would cost a little more: the authorisation fee for a UCITS, a UCI, a SIF or a SICAR would rise from €4,650 to €5,700 (+22.6%), and from €9,250 to €11,500 (+24.3%) for a multi-compartment structure.
Annual fees would follow the same pattern. A standard fund would move from €4,650 to €5,700, while umbrella funds would pay on a sliding scale depending on the number of sub-funds – from €11,500 for up to five compartments to €49,500 for more than fifty (compared with €9,250 and €40,500 today).
Managers face the same kind of increase. For AIFMs and management companies, several authorisation fees would rise from €18,000 to €22,000, and some annual fees from €42,000 to €51,500, a change that will concern a significant part of the Luxembourg fund industry.
The increase also applies to the fees introduced only in January 2026 for newer activities, which would be revised less than a year after they were created. A CASP’s authorisation would rise from €33,000 to €40,000, with its annual fee moving from €41,000 to €50,000; a DLT trading-and-settlement system from €50,000 to €61,000 for an operator that is already authorised (and €92,000 to €112,000 for a new one).
Our team is following this draft regulation closely and would be glad to help you assess what it means for your own structures and budget. If you have any questions or would like tailored advice, please do not hesitate to get in touch.
Photo – Rosc Art
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