The Luxembourg regulatory landscape continues to evolve with updated reporting requirements for investment funds. Here's a comprehensive breakdown of the latest changes that fund managers need to be aware of.

CSSF-Authorized Investment Funds

All investment funds authorized by the CSSF are now required to submit to Banque centrale du Luxembourg (BCL), the report S 4.4 (Country of Marketing). This requirement applies without exception to all CSSF-authorized funds, regardless of their size or structure.

Alternative Investment Funds (Non-CSSF Authorized)

For non-CSSF authorized alternative investment funds, the BCL reporting requirements are more nuanced:

Derogation Threshold

- The BCL has introduced a derogation threshold of EUR 300 million

- Funds below this threshold may be granted exemption from S 4.4 annual reporting obligations

- For multi-compartment funds, the threshold applies to the combined total assets of all compartments

Alternative investment funds that exceed the threshold or do not qualify for derogation must submit Report S 4.4 to BCL.

The content of the report

The report includes the shares/units issued by the investment funds broken down by countries of marketing with an estimate of the percentage of units/shares placed by country.

The template of of the S 4.4 report in the Excel format can be found here.

Timing and Submission Requirements

The report S 4.4 must be submitted on an annual basis. Reports are due within 14 weeks following the end of the reporting period.

The first report needs to be submitted for the year ending December 2025. The deadline for the submission is 8 April 2026.

You can find the full 2025 calendar for BCL reporting here.

How We Can Help

Nexly offers a platform for the full automation of BCL/CSSF reporting, including:

• Automatic generation of reports compliant with BCL/CSSF requirements.

• Automatic error detection

Contact us for a demonstration and to learn how we can streamline your regulatory reporting process.