Report S 2.20 - New BCL Reporting Requirements for AIFs Funds in Luxembourg

Overview

The Banque Centrale du Luxembourg (BCL) has introduced new reporting requirements for Non-Authorized Alternative Investment Funds (NAFs)—funds not supervised by the Commission de Surveillance du Secteur Financier (CSSF). The key requirement is the quarterly report S 2.20.

Content of the report

The template of the report in Excel format can be downloaded here.

Reporting Frequency

NAFs are required to submit Report S 2.20 quarterly, with a deadline of 20 working days following the end of each quarter.

The first reports will cover the quarter ending December 2025, with a submission deadline of 30 January 2026.

Derogation for Smaller Funds

• Asset Threshold Exemption
  NAFs with total assets under €300 million may qualify for an exemption from both monthly and quarterly reporting requirements.

• Multi-Compartment Funds
  For funds with multiple compartments, the €300 million threshold applies to the combined assets of all compartments.

Submission Calendar

The 2025 BCL reporting calendar for investment funds is available here.

How We Can Help

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

• Automatic generation of reports compliant with BCL requirements.

• Automatic error detection

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