Launch of the 2024 ESMA data collection on costs linked to investments in AIFs and UCITS

As part of the AIFMD/UCITSD review Directive, Art. 1 (amending Art. 12 of the AIFMD) and Art. 2 (amending Art. 14 of the UCITSD) require ESMA to submit a report to the European Parliament, the Council, and the Commission by October 2025 assessing the costs charged by UCITS management companies and AIFMs to investors of the UCITS/AIFs they manage, explaining the reasons for these costs and any differences between them, including differences related to the nature of the UCITS/AIFs involved.1

For this purpose, the competent authorities are required to provide ESMA with data on costs. This includes all fees, charges, and expenses directly or indirectly borne by investors, or by the UCITS or the AIF investment fund manager in connection with the operation of the UCITS/AIF, and those directly or indirectly allocated to the UCITS/AIF.

To this end, the competent national authorities are asked by ESMA to collect data at the level of UCITS and AIF investment fund managers (manufacturers) as well as distributors (i.e. investment firms, credit institutions, independent financial advisors, neo-brokers) in order to provide it to ESMA.

ESMA is expected to submit the report to the European Parliament, the Council, and the European Commission by 16 October 2025. This one-off report will form part of the enhanced 2025 market report on the Costs and Performance of EU Retail Investment Products.

In this context, the CSSF will launch, by the end of November 2024, a data collection exercise requesting a sample of UCITS and AIF investment fund managers as well as distributors to complete a specific questionnaire. A representative selection of Luxembourg-based UCITS and AIF investment fund managers, as well as of distributors, will soon be contacted by the CSSF for this purpose.

To ensure a secure exchange and to allow pre-submission data quality checks, the responses to the questionnaire must be submitted via the CSSF’s eDesk Portal. A dedicated section for completing this questionnaire will soon be available on the portal.

Technical details and deadlines will be communicated directly to the selected entities in the course of the exercise.

In addition, any further guidance from ESMA that becomes available will be provided to the selected entities.