CSSF guidance for Luxembourg IFMs on white-label business

On 8 October 2026, the CSSF published a new notification form with additional requirements for Luxembourg Investment Fund Managers (IFMs, including authorised AIFMs and UCITS management companies) that manage or intend to manage a fund at the initiative of a third party.

According to the Law of 12 July 2013 on alternative investment fund managers (the “AIFM Law”) and/or the Law of 17 December 2010 relating to undertakings for collective investment (the “UCI Law”), where a Luxembourg IFM manages or intends to manage a fund at the initiative of a third party, including cases where that fund uses the name of a third-party initiator or where an IFM appoints a third-party initiator as a delegate, the IFM must submit detailed explanations and evidence of its compliance with these articles to the CSSF. The CSSF published a new dedicated information form on its website “CSSF Information Form Lux IFM white-label business”. If an IFM wishes to perform this activity for the first time, it must complete and submit it to the CSSF, and the CSSF can request additional information about the initial notification at any time.

The CSSF requests the following information:

• Business model: Description of the white-label business model, including the partners/initiators involved, their objectives, fund types and growth targets; organisational, governance and monitoring arrangements ensuring regulatory compliance; and fee arrangements, including allocations to stakeholders and whether paid by the IFM or the fund. Where existing assets are taken over, a specific appendix must also be completed.
• Conflicts of interest policy, register and disclosure requirements: Confirmation that the conflicts of interest policy covers the white-label business, that relevant conflicts, including those arising from AIF management, are identified and recorded in the register, and that conflicts which cannot be prevented or managed are disclosed to investors before acting on their behalf, with appropriate policies and procedures in place; and proper examples of disclosures demonstrating compliance with the applicable AIFM Law and/or UCI Law requirements.
• Specific situations due to white-label business: Detailed explanations of how conflicts of interest arising in the following white-label arrangements are identified, managed and, where relevant, disclosed:
  1. Partners/initiators acting as investment advisers: the governance arrangements and controls applied to their advice before investment decisions are taken, including the IFM’s independent assessment and effective challenge where it also performs portfolio management.
  2. Partners/initiators acting as portfolio managers: how the IFM ensures that it has sufficient resources, expertise and independence to exercise effective oversight and perform the required controls.
  3. Portfolio management retained by the IFM: how the IFM ensures that investment decisions remain independent of the initiator’s formal or informal guidance or instructions and are taken exclusively in the best interests of the fund and its investors.
  4. Potential influence over asset valuation: how the IFM addresses attempts by partners/initiators to influence valuations and safeguards the independence of the valuation process.
  5. Overlapping responsibilities and appointments: which conflicts arise within the organisation from board memberships, participation in investment or valuation committees, involvement in decisions concerning affiliated delegates or service providers, participation in or oversight of control functions, and concurrent IFM and fund board roles, together with the measures applied to address those conflicts.

Appendix 1 requires AuM figures in EUR, with the relevant reference date, broken down by fund category and CSSF authorisation status, covering:

1. 1. Total AuM attributable exclusively to white-label/third-party initiated structures.
   2. AuM of funds operating under the third-party sponsor’s/initiator’s name, brand or commercial designation.
   3. AuM of funds for which the sponsor/initiator acts as delegated portfolio manager.
   4. AuM of funds for which the sponsor/initiator acts as investment adviser.

This new CSSF form supports the requirements introduced by the Law of 3 March 2026 in Article 13(2a) of the AIFM Law and Article 111(2) of the UCI Law.

Get in touch with our Luxembourg Team to discuss how these developments may impact your strategy and how we can support you with structuring, regulatory engagement, and compliance readiness.