LINARI LAW

Luxembourg Parliament Adopts Bill No. 8628 Implementing AIFMD II

The Luxembourg Parliament has approved (in a first vote on February 12, 2026 and being dispensed of  a second vote by the Council of State on February 25) Bill No. 8628, which transposes the EU Directive 2024/927 (AIFMD II) into national legislation. This new framework introduces significant updates to the regulation of Alternative Investment Fund Managers (AIFMs) and UCITS (Undertakings for Collective Investment in Transferable Securities), with a focus on enhancing market stability and investor protection within the EU.

Key Updates Under AIFMD II:

  • Loan Origination: AIFs are now explicitly authorized to grant loans, creating a harmonized legal environment for this activity across the EU. This change presents an opportunity for Luxembourg to expand its role in the private debt market by offering new investment strategies based on standardized rules.

 

  • Liquidity Management Requirements (LMTs): AIFMs will be required to adopt at least two liquidity management tools from an approved list, ensuring that funds are better prepared to manage liquidity risks.

 

  • Delegation Rules Strengthened: The law introduces more stringent requirements to disclose detailed information regarding the delegation and sub-delegation of functions to third parties. This harmonization between AIFMD and UCITS delegation frameworks aims to increase transparency and regulatory oversight.

 

  • Cross-Border Services & Marketing The reform enhances cooperation between national competent authorities and clarifies procedures for Cross-border management, Cross-border marketing and Supervisory information exchange

 

  • Depository Passport: A new provision allows AIFs from certain EU member states facing limited competition in depository services to choose a depository located in another EU country.

The new provisions are set to take effect on 16 April 2026, after the law’s publication. AIFMs will need to revise their policies, procedures, and fund documentation to ensure full compliance with the updated regulations.

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 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