Luxembourg Launches Transposition of AIFMD II – Draft Bill No. 8628 Introduced to Parliament
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.
The Bill is expected to enter into force on 16 April 2026, with reporting obligations applying from April 2027.
Luxembourg’s balanced transposition underscores its commitment to regulatory clarity and investor confidence.
