New CSSF eDesk Notification Requirements for Redemption Suspensions (LMT Rules)
As from 21 September 2026, the CSSF requires certain Luxembourg investment funds to notify the activation and deactivation of a suspension of redemptions only through the “LMT activation” module on the CSSF eDesk platform.
The new procedure applies to Luxembourg-domiciled funds governed by the amended Law of 17 December 2010 relating to undertakings for collective investment (UCIs), SIFs and SICARs .
The change forms part of the broader implementation of the liquidity management requirements introduced by the Law of 3 March 2026, which transposed Directive (EU) 2024/927, commonly referred to as AIFMD II.
Importantly, a suspension of redemptions only, where subscriptions remain possible, does not itself qualify as a Liquidity Management Tool (LMT) under the AIFMD II. The CSSF has nevertheless incorporated this type of suspension into the existing “LMT activation” module in order to centralise and simplify regulatory notifications.
Accordingly, funds concerned must use the eDesk module both when a redemption suspension is activated and when it is subsequently lifted.
The change concerns the notification channel only. Existing administrative requirements remain unchanged. In particular, any supporting documents required in connection with a suspension must continue to be submitted to the CSSF through the usual communication channels.
The new procedure applies specifically to Luxembourg-domiciled UCIs, SIFs and SICARs. RAIFs are therefore not directly within the scope of this specific “redemption-only suspension” notification requirement. However, where a RAIF qualifies as an open-ended AIF and is managed by a Luxembourg-authorised AIFM, its AIFM remains subject to the broader LMT framework introduced by the AIFMD II, including the applicable requirements concerning the selection, activation and deactivation of LMTs and related CSSF notifications.
Fund managers and administrators should ensure that their internal liquidity-management and suspension procedures have been updated to reflect the new eDesk notification route and that responsibility for making the relevant CSSF filing is clearly allocated. Our team 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.
