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By Dr. Sebastiaan Niels HOOGHIEMSTRA, Loyens Loeff Luxembourg *
On 19 December 2025, the CSSF issued Circular 25/901 (the “Circular”), a major overhaul that modernizes, clarifies and simplifies rules for all CSSF-regulated investment funds (“Regulated Funds”), including SIFs, SICARs and Part 2 UCIs. It repeals long-standing circulars, renders others inapplicable, and introduces a general glossary to streamline communication with the CSSF. While primarily targeting SIFs, SICARs and Part 2 UCIs, the Circular is also (partly) relevant for RAIFs. This piece focuses on the new requirements and their impact on the democratization of alternatives for Part 2 UCIs.
Investment limits Risk-based investor categorization
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