Based on the new ECB EU Regulation (2024/1988 of 27 June 2024) concerning statistics of investment funds, the BCL, in agreement with the CSSF, has introduced modifications to regulatory reporting requirements for the following types of funds UCITS, UCI, Part II, SIF, SICARs, and RAIFs.

As of 1 December 2025, the threshold for BCL reporting will be reduced from EUR 500 millions to EUR 300 millions.

Modifications to Existing BCL Reports

• TPTOBS: New items have been introduced in monthly security-by-security reporting.

• S 1.3: New items have been added to the monthly balance sheet reporting.

• S 2.13: New items have been added to the quarterly balance sheet reporting.

You can download an Excel file with detailed changes to the layout of the TPTOBS, S 1.3, S 2.13, and TPT reports here (Source: BCL).

Newly Introduced BCL Reports

• S 2.20: A quarterly report to collect financial information on alternative investment funds not authorized by the CSSF.
  You can download an Excel template of the S 2.20 report here.

• S 4.4: An annual report to collect data on the countries where a fund's shares or units are marketed. The report must be provided by all investment funds authorised by the CSSF.
  You can download an Excel template of the S 4.4 report here.

Modifications to CSSF Reporting

• U.1.1: New items have been added to the U1.1 monthly reporting.

• O 4.1, O 4.2 and K 3.1: These reports will be discontinued as of 1 December 2025.

Deadlines for the First Submission of Updated Reporting

Non-Money Market Funds

The first submission of updated reporting for non-money market funds will cover the reporting period ending in December 2025.

• S 1.6 and S 2.13: Reports for December 2025 must be submitted by 30 January 2026.

• TPTOBS: Reports for December 2025 must be submitted by 30 January 2026.

• S 2.20: Reports for December 2025 must be submitted by 30 January 2026.

• S 4.4: The annual report for December 2025 must be submitted by 8 April 2026.

Note: Report S 1.6 is not mandatory if non-financial assets or financial derivatives represent less than 5% of total assets. Report S 2.20 is only mandatory for alternative investment funds not authorized by the CSSF (NAFs).

Money Market Funds

The first submission of updated reporting for money market funds will cover the reporting period ending in December 2025.

• S 1.3: Reports for December 2025 must be submitted by 15 January 2026.

• TPTOBS: Reports for December 2025 must be submitted by 15 January 2026.

• S 4.4: The annual report for December 2025 must be submitted by 8 April 2026.

Timeline for Implementation

The timeline for implementing the updated BCL reporting requirements is as follows:

Test transmissions can begin as early as August 2025, providing sufficient preparation time for stakeholders to ensure full compliance.

Source: https://www.bcl.lu/en/Regulatory-reporting/Fonds_Investissement/Instructions/index.html

Preparing for the Transition

We provide fully automated solutions for the new reporting requirements, ensuring seamless compliance and operational efficiency.

Schedule a demo today to see how we can simplify your BCL and CSSF reporting process.