Anne-Gaëlle Delabye
Partner | Legal
Luxembourg - Legal Services
Anne-Gaëlle Delabye
Partner
Luxembourg - Legal Services
CSSF Circular 25/900: new reporting landscape for UCI administrators
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Significant updates have been made to the annual reporting requirements for administrators of undertakings for collective investment (UCIA) in Luxembourg, following the issuance of Circular 25/900 by the Luxembourg financial regulator (the CSSF).
Circular 25/900 (the Circular) amends Circular 22/811 relating to the authorisation and organisation of entities acting as UCIAs. The new Circular also clarifies certain requirements, notably on the outsourcing of information and communication technologies (ICT) in light of the Digital Operational Resilience Act (DORA).
The new framework becomes effective for financial years ending on or after 31 December 2025.
Key changes
Streamlined and simplified annual reporting
The updated regime introduces a more streamlined approach to annual reporting for UCIAs (UCIA Report):
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the previous reporting requirements are replaced by a simplified, core compliance-focused self-assessment questionnaire (SAQ)
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reporting on UCIAs’ business activities and resources is substantially reduced
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Annex B of Circular 22/811 has been repealed and will be replaced by new reporting modalities detailed on the CSSF website
Integration with other regulatory reports
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For credit institutions, investment fund managers, certain support professionals and investment firms acting as UCIAs, their UCIA Report is now integrated into their existing annual long-form reports / self-assessment questionnaires (LFRs / SAQs) - these entities will not submit a separate UCIA Report
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Specialised professionals of the financial sector (PFS) acting as UCIAs must submit relevant UCIA sections in their annual self-assessment questionnaire (PSF-SP SAQ) via the CSSF eDesk platform
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Other UCIAs will continue to use the UCI Administrator Reporting Tool (UCIA RT) on CSSF eDesk for their reporting obligation
Reporting deadlines
For the majority of UCIAs, the UCIA Report (via the UCIA RT) must be submitted at the latest five months after the end of the financial year.
For specialised PFSs acting as UCIAs, the deadline for submitting the PSF-SP SAQ is 31 March 2026 for those with financial years ending on or after 31 December 2025.
ICT / outsourcing – DORA alignment
Circular 22/811 has also been amended to align with the new requirements under the entry into force of the DORA, effective January 2025. Accordingly, UCIAs which are in scope of DORA (credit institutions, investment fund managers, investment firms and certain ICT-related support professionals) must comply with DORA and Circular 25/882 for ICT outsourcing arrangements, whereas other UCIAs remain subject to the ICT risk management requirements of Circular 20/750.
Entry into force
The new framework applies for all financial years ending on or after 31 December 2025. UCI administrators who fall within the scope of the Circular must use the revised reporting framework going forward.
Next steps
These developments mark a further step in strengthening regulatory reporting and digital resilience in the Luxembourg funds sector. UCIAs should promptly assess where they stand under the updated framework, review their reporting practices, and ensure that their compliance and ICT controls are fully up to date.
How Ogier can help
Our dedicated Investment Funds team in Luxembourg can advise UCIAs on compliance with the new requirements. For more information, please reach out to the team listed below.
About Ogier
Ogier is a professional services firm with the knowledge and expertise to handle the most demanding and complex transactions and provide expert, efficient and cost-effective services to all our clients. We regularly win awards for the quality of our client service, our work and our people.
Disclaimer
This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.
Regulatory information can be found under Legal Notice
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