National marketing rules for AIFs in Luxembourg

Luxembourg AIFMs wishing to market EU AIFs to professional investors in Luxembourg, if those AIFs are managed by the same AIFM but established in another Member State, must send a notification package to the CSSF through its eDesk portal.
The notification must include documentation outlined in Annex III of the Luxembourg AIFM law (including strategy, service provider information, valuation, liquidity risk management, fee structure, investor protection measures, annual reports, NAV, etc.).
The CSSF has 20 working days to respond after receipt of a complete file. If positive, the AIFM can start marketing the AIF; if not, CSSF may restrict marketing if legal compliance is not met.
If there are material changes to the original notification, the AIFM must inform the CSSF at least one month prior to implementing planned changes—or immediately if changes were unplanned.
AIFMs can also withdraw (“de-notify”) previously notified marketing arrangements; in that case, a de-notification letter must be submitted via eDesk.
The CSSF requires that marketing communications be clearly identified as marketing, and that they present risks and potential rewards of investing in the AIF in a balanced, fair, clear, and non-misleading way.

Luxembourg AIFMs wanting to market EU AIFs to professional investors in other EU member states must submit a notification to the CSSF (under Annex IV of the AIFM law).
CSSF will then forward the complete notification file to the relevant host Member State’s authority and notify the AIFM when marketing may begin.
Material changes to the notification must be reported in advance (or immediately if unplanned), similar to domestic passporting.
De-notification processes apply, and the CSSF will convey de-notification to the host Member State as appropriate.

EU-authorised AIFMs seeking to market non-EU AIFs in Luxembourg to professional investors must submit an information form to the CSSF via email (aifm@cssf.lu).
If the marketing ends, the AIFM must inform the CSSF whether Luxembourg investors are still invested, and deregister the fund/sub-fund accordingly.

Non-EU AIFMs wishing to market AIFs (regardless of their jurisdiction or regulation) to professional investors in Luxembourg must submit an information form to CSSF (aifm@cssf.lu).
Deregistration (“de-notification”) rules apply similarly, with notification to CSSF when marketing ceases.
Even after de-registration, a non-EU AIFM must continue to comply with AIFMD Annex IV reporting obligations toward Luxembourg as long as Luxembourgish investors remain invested in the fund.

To market foreign AIFs to retail investors in Luxembourg, an AIFM must secure prior authorisation from the CSSF, under Luxembourg’s CSSF Regulation No 15-03.
The authorisation request form — and any subsequent updates — must be sent to the CSSF via “opc@cssf.lu".
Deregistration procedures apply in the same way: marketing cessation must be notified, and the CSSF must be informed whether Luxembourg investors continue to hold positions.

Documents submitted to CSSF (and information provided to investors in Luxembourg) must be in one of Luxembourg’s official or financial languages: Luxembourgish, French, German, or English.
The CSSF expects that marketing communications be clear, fair, risk-balanced, non-misleading, and that they properly disclose investment risks and rewards.
The CSSF can request proof of payment of fees charged for notification or marketing activities. Notification files should be kept concise — large submissions may face processing delays.
Additional national laws (e.g. consumer protection, advertising regulation) may apply to marketing AIF units in Luxembourg, outside the scope of the AIFM Law, and firms should assess these on a case-by-case basis.

Summaries of national provisions governing the marketing requirements for AIFs