Agefi Luxembourg - janvier 2026

AGEFI Luxembourg 22 Janvier 2026 Fonds d’investissement By Alessia BERARDI, Head of Emerging Macro Strategy,Amundi Investment Institute I ndia is undergoing one of the most significant economic and financial transformations of the decade, propelled by structural re- forms, rising domestic demand and a rapidly deepening capital market.As geopolitical fragmentation reshapes global investment strategies, India stands out as a rare combination of high growth, improving di- versification benefits and ex- pandingmarket accessibility. Overthepast10years,Indiahasshift- ed from a largely services driven economy to one pursuing a more bal- ancedmodelanchoredinmanufacturing, digitalization and strategic trade. The gov- ernment’s efforts to build domestic industrial capa- bilities have already delivered tangible results, par- ticularly in electronics, semiconductors anddefense. In 2014, India imported roughly three-quarters of itsmobile handsets, when today, that share has fall- en close to zero, with exports rising sharply. Defense procurement has also shifted markedly: 60% of capital purchases now come from domestic suppliers, supported by policy reforms that encourage private sector innovation andmandate local sourcing. This manufacturing pivot is rein- forced by sweeping improvements to infrastructure, logistics and the ease of doing business. Production linked incentives, newindustrial parks and stream- lined permit processes are help- ing attract foreign direct invest- ment and foster amore competi- tive environment for local firms. At the same time, India is acceler- ating the development of a domes- tic semiconductor industry, backed bymore than $18 billion in ongoing projects aimed at reducing depen- dence on foreign chipmakers. Butthestructuraltransformationextendsbeyondsup- ply-side reforms. The India consumption story is undergoing an interesting transformation. Rising incomes, urbanization anddigital adoption are shift- ing spendingpatterns fromessential goods todiscre- tionary andpremiumcategories. Higher penetration of appliances such as air conditioners anddishwash- ers, booming domestic tourism and record levels of outbound travel illustrate this lifestyle shift. Premiumizationisespeciallyvisibleintheautomotive vehicles, where entry-level models have dropped from70%of sales in 2014 to just 31%today. Fiscal measures are reinforcing these trends.Amajor simplification of the Goods and Services Tax (GST) regime aims to cut compliance costs, broaden the tax base and stimulate household consumption. Lower taxes on mass-market goods should have a disinfla- tionaryeffect andprovide roomfor theReserveBank of India to easemonetarypolicy further in 2026. For global investors, India’s transformation is not only economic but strategic. As supply chains are rewired and geopolitical blocks consolidate, corre- lations across major markets have declined. Both Indianequities andbonds exhibit relatively lowcor- relationwithdeveloped-marketandbroaderemerg- ing-market indices, enhancing their diversification value in global portfolios. The long-term investment case is compelling. According to Amundi’s 2025 Capital Market Assumptions, Indiangovernment bonds are expect- ed to deliver annual USD returns of around 7.5% over the next decade, the highest in the global fixed- income universe considered. Equities are projected to return about 8% annually, supported by strong earningsgrowthand India’spredominantlydomes- tic revenue base, which helps insulatemarkets from external shocks. Market access, historically constrained for foreign investors,isalsoimprovingrapidly.India’sinclusion in the JPMorganGBI-EMIndex in2024has boosted passiveflows,whileongoingreformsaresimplifying licensing processes and reducing operational fric- tions. A growing domestic investor base, including pension funds and retail savers, adds further depth and resilience to Indianmarkets. Short-termheadwinds remain, including softer pri- vate investment momentum, FX volatility and lin- gering global trade tensions, notably with the United States. Yet India’s medium-term outlook remains robust, with GDP growth expected to stay above 6%and inflation anchoredwithin the central bank’s target band. In a world defined by geopolitical fragmentation, India is positioning itself as a long-term winner: a manufacturinghub,aconsumptionpowerhouseand a vital diversification engine for global portfolios. For investors seeking for growth, resilience and strategic optionality, India’s transformation is creating oppor- tunities that are difficult to ignore. India’s economic transformation creates new opportunities for global investors By Francesco D’A VANZO , Regulatory Compliance & AML/CFTProfessional – Investment Fund industry T he annual investment fundmana- gers’ (IFMs) self-assessment ques- tionnaire (SAQ) has undergone a steady evolution since its introduction in 2021.Acomparisonbetween the original ver- sion and themost recent version (i.e. covering the exercise enddate from 31December 2025 to 30November 2026) shows a clear process of refi- nement over time.While the majority of the sections of the SAQhave been subject only to minor adjustmentswithout substantive changes, other sec- tions have been significantly strengthened through the inclu- sionof newquestions or changes to their structure.Moreover, additional sections have alsobeen introduced compared to the origi- nal form. The reasons for these refinements appear tobemainlydrivenby the introduc- tionof newregulations after 2021.As a result, it canbe affirmed that the latest versionof the SAQis considerablymore comprehensive andprobing than its original 2021 version. CSSF Circular 21/798, as amended by CSSF Circular 23/839, was issued in late December 2021 and intro- duced a new annual regulatory reporting require- ment for IFMs in the formof a self-assessment ques- tionnaire, requiring IFMs to assess their compliance with applicable legal and regulatory requirements, primarilyderived fromCSSFCircular 18/698. This article aims toexamine the evolutionof theSAQ pro forma from 2021 to 2025, highlight the main changes introduced over time, and analyse the regu- latory rationale underpinning those changes, which collectivelyreflectashifttowardsmoregranular,risk- focused anddata-driven supervisory oversight. Introduction of dedicatedMiFID andUCIAAdministration sections The original SAQ (i.e. covering the exercise end date from 31 December 2021 to 30 November 2022, here- after referred to as “SAQ2021”), consisted of ten sec- tions andbroadly followed the order of topics set out inCSSFCircular 18/698. Themost recent version of the SAQ (i.e. covering the exercise end date from 31 December 2025 to 30 November2026,hereafterreferredtoas“SAQ2025”) hasbeenexpandedtoincludetwoadditionalsections dedicated respectively to MiFID (Section XI) and UCIAadministration(SectionXII).TheMiFIDsection wasfirst introduced in the SAQcovering the exercise end date from 31 December 2024 to 30 November 2025 (hereafter “SAQ 2024”), while the UCIA administration section was added one year later in the latest version of the questionnaire. The introduction of a dedicated MiFID section in SAQ 2024 replaced the limited MiFID-related questions that were pre- viously included under the “other requirements”section(Section X). This evolution reflects the CSSF’s shift fromvery narrow MiFID activity checks under the SAQ 2021, towards a more comprehensive MiFID II conduct of business supervisory approach under the SAQ 2024. This dedicated section thus enables the CSSF tomonitor theactivitiesof IFMs holding the so-called “top-up”MiFID license, whose scope of activity extends beyond the default functions permitted to IFMs under fund manage- ment legislation. By contrast, the UCIA administration section allows the CSSF to monitor IFMs that fully or partially per- formoneormoreofthethreecoreUCIadministration functions. Its inclusion appears to be driven by the need to assess the level of compliance, among IFMs holding a UCIA administration license, with CSSF Circular22/811,asamendedbyCSSFCircular25/900. Both sections further contain a specific sub-section intended for the collection of quantitative data and factual information, thereby enhancing the CSSF’s ability toperformcomparativeandrisk-basedsuper- visory analysis. Expansion of the Information Technology section Among the ten sections of the original SAQ 2021, the “information technology” section (Section VIII) is the one that has undergone the most extensive revision. In its initial form, this section comprised only seven parts, focusing on general organization, IT riskmanagement, IT sourcing, IT cloud, IT conti- nuity, IT security, and IT changes in critical IT envi- ronments. On the other hand, in the SAQ 2025, the IT section is significantly more structured and sub- stantially reinforced. This expanded approach reflects the issuance and progressivedevelopment of EUlegislationandCSSF circularsbetween2022and2025,whichhavestrength- ened regulatory expectations in relation to IT gover- nance, ICT risk management, outsourcing arrange- ments, andoperational resilience. The core legislative backbone of the IT section derives fromboth EU leg- islation (Regulation (EU) 2022/2554 (DORA) and Commission Delegated Regulation (EU) 2024/1774) and the Luxembourg supervisory framework (CSSF Circular22/806,asamendedbyCircularCSSF25/883; Circular CSSF 21/769, as amended by Circular CSSF 22/804; and Circular CSSF 20/750, as amended by CircularsCSSF 22/828 and 25/881). Inthiscontext,theterminologyhasevolvedfrom“IT” to the broader concept of “ICT”. As a result, the IT section of SAQ2025 is composed of nineteen distinct parts, covering, inter alia: general organization, ICT landscape, ICT risk management, ICT third-party providers, ICT internal audit, ICT in the context of portfoliomanagement andadministration functions, ICT operations, physical security controls, identity and access management, network security, malware prevention, access and authentication, change and releasemanagement, projectmanagement, ICTsolu- tionslifecycle,ICTbusinesscontinuity,backups,inci- dent and problem management, and digital opera- tional resilience testing. Reconfiguration of the Other Requirements section Another section that has undergone noteworthy changes is the “other requirements” section (Section X). In its original form under SAQ 2021, this section addressed threemain topics, presented in the following order: IFM branch activities, MiFID services, and domiciliation services.With the introduction of SAQ 2024, MiFID-relatedmat- terswere transferred to the newly created dedicat- ed MiFID section (Section XI), resulting in the removal of the few MiFID service questions - focused almost exclusively on the discretionary portfolio management (DPM) service - from the “other requirements” section. In addition, ques- tions relating to the IFM’s domiciliation agent activity were entirely removed. Moreover, a new subsection entitled “third-party / white-label business” was added in the SAQ 2024. This subsection includes a question aimed at deter- miningwhether the IFMengages in such activities— namely, whether itmanages aUCI at the initiative of a thirdparty, includingcaseswhere theUCI operates under the name of a third-party initiator or appoints such a thirdparty as delegate or investment advisor. Overhaul of theRemuneration section The “remuneration” section (SectionVI Bis) has also been subject to an overhaul. In the SAQ 2021, this section included only four questions, which reflect- ed the core remuneration rules set out in Directive 2011/61/EU (AIFMD) / Directive 2009/65/EU (UCITS), and ESMA Guidelines on sound remu- neration policies. These questions were primarily designed to assess whether the structure and pay- ment conditions of variable remuneration complied with applicable regulatory requirements, in partic- ular by limiting incentives for excessive risk-taking, preventing circumvention of remuneration rules through alternative payment vehicles or methods, andensuring that remuneration requirementswere appropriately applied in the context of delegation arrangements. With the SAQ covering the exercise end date from 31 December 2022 to 30November 2023, hereafter referred to as “SAQ 2022”, this section was revised from a predominantly binary (“yes/no”) format to a more data-driven approach. In this regard, the SAQ 2022 required IFMs, for example, to specify how many of their “identified staff” received variable remuneration, how many of them received variable remunerationwithin spec- ified percentage ranges of total annual remuner- ation, and to indicate the shortest deferment peri- od applicable to variable remuneration payments. Subsequent SAQs following the SAQ 2022, do not reflectfurthersignificantmodificationstothissection. Refinements to Procedures and Policies section The “procedures and policies” section (Section VI) has also been subject to revisions over the years. In its original form, the SAQ 2021 enquired about the existence and the date of the last review of a set of key IFMpolicies andprocedures, notably including complaintshandling, personal transactions, conflicts of interest, code of conduct, remuneration, voting rights, and product governance. The questionnaire then delves further into specific questions concern- ing the handling of complaints and claims, personal transactions andconflict of interest, suchaswhether anycomplaintsorclaimswerereceivedandwhether anypersonaltransactionsorconflictsofinterestwere identified during the reference period. In the SAQ 2023, a SFDR-specific policy question was introduced in this section, asking whether the IFMhad adopted a policy or procedure supporting the sustainable investments made by the funds it manages and ensuring that such investments com- plywith the definition of “sustainable investment” set out in the SFDR. This addition appears to be justified by the entry into force of the SFDR in March 2021. In the SAQ 2025, the same section also included “approval of new business relationships and new products” among the key set of IFM policies and procedures whose existence was assessed. Conclusion As stated above, the IFM self-assessment ques- tionnaire primarily serves as a supervisory tool for assessing IFMs’ compliance with regulatory requirements which are largely derived from CSSF Circular 18/698. Its progressive expansion and increasing level of granularity reflect both the development of the applicable regulatory frame- work and the CSSF’s evolving supervisory prior- ities, notably towards more data-driven and risk- based oversight. It will therefore be of particular interest to observe whether, and if so how, this annual regulatory reporting exercise will further evolve following the expected release of the revised version of CSSF Circular 18/698. Five years of the IFM Self-Assessment Questionnaire: an examination of its evolution