{"id":"circulars/cssf-26-910","title":"Circular CSSF 26/910","type":"circular","date":"2026-04-15","kind":"circular","html":"

Circular CSSF 26/910 is a CSSF circular, published 15 April 2026. Subject: ESMA Guidelines on Liquidity Management Tools (LMTs) of UCITS and open-ended AIFs (ESMA34-671404336-1364).

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Relevant for: AIFMs, Investment fund managers, Investment funds and vehicles, Management companies - Chapter 15, Management companies - Chapter 16, Other specific authorisations, registrations and information, Part II UCIs, Pension funds, Securitisation undertakings, SICARs, SIFs, UCITS.

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Keywords: AIF (alternative investment fund), Depositary, Investor protection, Liquidity, Money Market Fund (MMF), Risk management, UCI administration, UCI prospectus.

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Text

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Circular CSSF 26/910 ESMA Guidelines on Liquidity Management Tools (LMTs) of UCITS and open-ended AIFs (ESMA34-671404336-1364)

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Circular CSSF 26/910 ESMA Guidelines on Liquidity Management Tools (LMTs) of UCITS and open-ended AIFs (ESMA34-671404336-1364) To all Luxembourg investment fund managers, to all Luxembourg undertakings for collective investment and to those involved in the operation and supervision of such undertakings.

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Luxembourg, 15 April 2026 Ladies and Gentlemen, The purpose of this circular is to inform you that the CSSF, in its capacity as competent authority, applies the ESMA Guidelines on Liquidity Management Tools (LMTs) of UCITS and open-ended AIFs (ESMA34-671404336-1364) (the “Guidelines”), published on 12 March 2026, and is integrating the Guidelines into its administrative practice and regulatory approach with a view to promoting supervisory convergence in this field at European level. The

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Guidelines are

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attached

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this circular and

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are

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available on ESMA’s

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website

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https://www.esma.europa.eu/document/guidelines-liquidity-management-tools-ucits-and-openended-aifs.

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  1. The Guidelines Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024 (“Directive (EU) 2024/927”) amending Directives 2011/61/EU (the “AIFMD”) and 2009/65/EC (the “UCITS Directive”) as regards delegation arrangements, liquidity risk management, supervisory reporting, the provision of depositary and custody services and loan origination by alternative investment funds introduced, among others, requirements in relation to LMTs for UCITS and AIFMs managing openended AIFs. The AIFMD and the UCITS Directive are supplemented by Commission Delegated Regulations (EU) 2026/465 (pertaining to the AIFMD) and (EU) 2026/466 (pertaining to the UCITS Directive) with regard to regulatory technical standards (“RTS”), as referred to in Article 16(2g) of the AIFMD and Article 18a(3) of the UCITS Directive, specifying the characteristics of LMTs. Directive (EU) 2024/927 has been transposed into Luxembourg legislation by the Law of 3 March 2026, which amends the Law of 17 December 2010 relating to undertakings for collective investment (the “2010 Law”) and the Law of 12 July 2013 on alternative investment fund managers (the “2013 Law”). The Guidelines were developed on the basis of Article 16(2h) of the AIFMD, Article 18a(4) of the UCITS Directive and Article 16(1) of Regulation (EU) No 1095/2010 establishing a European Supervisory Authority (European Securities and Markets Authority). The purpose of the Guidelines is to establish guidelines on the selection and calibration of LMTs by UCITS and AIFMs for liquidity risk management and for mitigating financial stability risks. Whilst the primary responsibility for LMTs remains, in accordance with the Guidelines, with the UCITS and AIFMs, the purpose of the Guidelines is also to establish consistent, efficient and effective supervisory practices and to ensure the common, uniform and consistent application of Union law,
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in particular of Article 18a(2) of the UCITS Directive (Article 52-1(1) of the 2010 Law) and Article 16(2b) and (2c) of the AIFMD (Article 15-1(1) and (2) of the 2013 Law) in relation to the selection, activation and calibration of LMTs.

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  1. Scope The present circular applies to the following investment fund managers (“IFMs”) in respect of the UCITS and open-ended AIFs they manage: •
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management companies incorporated under Luxembourg law and subject to Chapter 15 of the 2010 Law;

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management companies incorporated under Luxembourg law and subject to Article 125-2 of

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Luxembourg branches of IFMs subject to Chapter 17 of the 2010 Law authorised under the

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UCITS investment companies which have not designated a management company within the

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AIFMs authorised under Chapter 2 of the 2013 Law; as well as

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internally managed AIFs within the meaning of point (b) of Article 4(1) of the 2013 Law.

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The text above is the opening of the document; the PDF carries the whole.

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Document page, PDF. Source: Commission de Surveillance du Secteur Financier (CSSF), reproduced with the CSSF's consent. The French text prevails.

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