On 3 October 2025, Luxembourg submitted Draft Bill No. 8628 to Parliament to transpose Directive (EU) 2024/927 (AIFMD II) into national law. The Bill amends the AIFM Law and the UCI Law, aligning Luxembourg’s framework with EU requirements while preserving its pragmatic regulatory approach.
Key points:
– Expanded services: AIFMs and ManCos may now offer credit servicing, benchmark administration, and ancillary services (e.g. risk, portfolio, or marketing) to third parties, including co-investment or securitisation vehicles.
– Loan-originating AIFs: New rules on diversification (20%), risk retention (5%), and leverage limits (175%/300%), with a ban on Luxembourg consumer loans.
– Delegation & substance: Codification of existing CSSF expectations without additional burdens.
– Liquidity management: AIFs and UCITS must use at least two harmonised tools, with flexibility to add others.
– Depositaries: Must remain Luxembourg-based.
– UCITS ETFs: Exemption from auditor reports for in-kind creations and redemptions.