Agefi Luxembourg - avril 2026

AGEFI Luxembourg 24 Avril 2026 Fonds &Marchés O n 4 February 2026, the Com- mission de Surveillance du Secteur Financier (the “CCSF”) confirmed a significant development for Luxembourg’s in- vestment fund industry by publi- shing a long-awaited FAQ on the treatment of crypto-assets in undertakings for collective investment (the “FAQ”). The clarification marks a piv- otal moment for portfolio con- struction in Luxembourg, reinforcing the country’s posi- tion as a forward-looking Eu- ropean fund domicile while aligning with the latest European reg- ulatory guidance. Historically, the CSSF has taken a cautious stance, considering crypto-assets not appropri- ate for all types of investors. However, the new FAQ introduces a more nuanced approach, confirming that UCITS may gain indirect ex- posure to crypto-assets, subject to strict con- ditions. In particular, such exposure is capped at 10% of the UCITS’s net asset value ( NAV ), ensuring that crypto-assets remain a limited and controlled component of the overall portfolio. A UCITS can achieve this indirect exposure through crypto ex- change-traded products (ETPs), complyingwith the requirements set out in the Grand-Ducal Regu- lation of 8 February 2008 on UCITS (the “ Regulation ”). Specifically, the crypto ETPmust not embed derivatives and must qualify as a transferable security within the meaning of the Regulation. In practice, crypto ETPs are typically structured as debt securities. When an investor acquires a crypto ETP, they make a payment to the issuer, which in turn provides economic exposure to the underlying crypto-asset. Upon sale, the in- vestor receives a return reflecting the market value of the underlying crypto-asset, subject to applicable fees. This structure enables indirect participation in crypto markets without direct ownership of the asset. To qualify as transferable securities underArticle 2 of the Regulation, crypto ETPs must meet a number of criteria. First, the potential loss for the UCITS is limited to the amount invested, thereby satisfying the re- quirement of limited liability. Second, these instruments generally benefit from strong liquidity, as they are listed on regulated markets such as major European exchanges, en- suring that UCITS can meet their redemption obligations to investors. Furthermore, reliable valuation is ensured through transparent market prices. Investors also benefit fromappropriate and comprehensive dis- closures. In addition, crypto ETPs are freely ne- gotiable on regulated markets, fulfilling the re- quirement of transferability. Finally, the risks associatedwith crypto ETPs can be properly identified, measured, and managed within the UCITS risk management framework. This ensures that such investments remain con- sistent with the regulatory expectations for risk control and investor protection. Conclusion In light of the FAQ, crypto ETPs meet the above definition according to the Regulation. UCITS may therefore gain limited indirect exposure to crypto-assets within their portfolios, provided all applicable regulatory requirements are satisfied. This marks a cautious yet meaningful step toward integrating crypto-assets into the traditional fund framework, balancing innovation with robust in- vestor protection. Francesco SEVERINO, LLM, MBA, RC Certificate, GFR RegulatoryComplianceandAML/CFTprofessional/InvestmentFundIndustry UCITS and Crypto-Assets ANew Era for Portfolio Construction in Luxembourg L uxembourg’s ManCo sector is accelerating into a new era where consolidation, scale and innovation converge to reshape how asset managers ope- rate and grow. Luxembourgisnotjustafunddomicile:it stands as a strategic command center for EuropeanAsset Management. It is home to nearly 300 authorized management companies (ManCos), (1) ranging from UCITS management companies and au- thorizedalternativeinvestmentfundman- agers (AIFMs) to fully licensed Super ManCos (which combine bothmodels). In recent years,ManCos have been facing regulatoryreforms,digitaltransformation, andmarginpressure.Theimplementation of the new texts (such as the reviewed UCITSDirectiveandAIFMD,DORAand theupcomingEURetailInvestmentStrat- egy) are reshaping how firms operate, govern and grow. At the same time, the ongoing reviewof SFDR and the shift to- ward a more coherent EU sustainability framework are redefining transparency requirements, pushing ManCos to en- hance ESG data, reporting processes and product governance. Ifwe take 2018 as our startingpoint, Lux- embourg’sManCo has come down from 316to289inearly2026. (2) Thisreflectsvar- ious trends in the sector, regulatory-dri- ven consolidation, unit economics, but especiallytheriseoflarger,multi-product third-party ManCos that can absorb in- creasing regulatory requirements more efficiently andoperate at scale. These dy- namics are amplified by persistent cost and margin pressures, reinforcing the need for economies of scale, mutualiza- tion of functions, and better integration across governance, distribution, and op- erational platforms. Despitethisconsolidationtrend,ManCos continued to grow, for instance in em- ploymentcapacity,employing7,805peo- ple in 2025 (3) (a growth of 36% compared to 2018 when this industry was employ- ing 5,705); and in number of branches (branches of the Luxembourg ManCos roseto296attheendof2025showingthat thesectoriscastingawidenetinEurope). What is more impressive is that assets undermanagementhavealmostdoubled inthesameperiod,hittingEUR6,3trillion witharoundEUR370billionmanagedon a discretionary basis. (4) A closer look at the ManCo numbers shows that 145 operate exclusively as managersof alternative investment funds and 144 are UCITS or Super ManCos managing both fund types. (5) This break- down highlights howmarket dynamism continuestoshapetheManCoecosystem, drivenespeciallyby the entryof newspe- cializedAIFMsandongoingconsolidation among more established firms. Further- more, whenwe look at the recentMerger &Acquisition(M&A)activity,wesee that it is mostly driven by scale ambitions, private-equity investments, and the ex- pansion of one-stop-shop service mod- els. In recent years, a growing number of private equity boutiques have ac- quired or taken stakes in Luxembourg ManCos, targeting midsized gover- nance platforms andAIFMswith strong privatemarkets capabilities and scalable operating models. As M&A activity centralizes operations within fewer but more capable entities, these ManCos host more funds and strategies under a single license and structure that can sustain largerAuMs at better cost metrics. Luxembourg’s regulatory environment and the rise ofmodernManCos Luxembourg’s regulatory environment has shaped the modern ManCo model by placing a strong emphasis on sub- stance and governance as early as 2018, well ahead of theUCITS andAIFMD re- forms that will apply in the coming months. With today’s perspective, this early move mirrors the expectations of today’sassetmanagers,whoincreasingly demand stronger governance, more ro- bust risk management frameworks, and disciplined valuation practiceswhile still requiring agility and flexibility. This po- sitioningalignswith the rolenowplayed bythelargestthird-partyManCos,which have become, in recent years, one of the central pillars of the Luxembourg asset management ecosystem. In parallel, the emerging role of AI in compliance, oversight, reportinganddis- tribution analytics is reshaping the oper- ating model of ManCos, requiring new digital capabilities alongside core gover- nance functions. Inside the operatingmodel: key numbers in the third-partymodel Third-party ManCos today collectively commands 18% (6) of the AuM market share in Luxembourg. This concentration underlines the institutionalization of the sector. Among the Top 20 third party ManCos, firms employ on average 82 FTEs (7) and have built strong internal ca- pabilities across core governance and oversight functions, including risk man- agement, compliance andvaluation. Growing adoption of one-stop-shop model further reinforces integratedoper- ating model among leading third-party ManCos, and is pushing them beyond traditional governance roles to deliver end-to-end services from fund set-up to portfoliooversight andall the services in- between. 17 out of top 20 third-party ManCos offer fund administration serv- ices either in-house or through a group- related company. Larger scale also comes with sophistica- tion.Third-partyManCostodayoverseea wide ecosystemof stakeholders: on aver- age, 7 fund administrators, 8 registrar/ transfer agents and 8 depositary banks. (8) Thesenumberscangoashighas30incer- taincases.Thosecapableofmasteringthis complexitythroughsustainedinvestment in talent and digital transformation are best positioned to emerge as one of the premiuminvestmenthouses,withpoten- tialtodominatetheEuropeanSingleMar- ket in the next decade. Indeed, this shift requiresnotonlytechnology,butalsospe- cialized talent, data analysts, digital over- sight experts, ESG specialists, and private marketsprofessionals,allofwhicharebe- coming critical skillsets in the Luxem- bourg ecosystem. As product ranges expand in volume and complexity, fromprivatemarkets to semi-liquid retail solutions, differentia- tion increasinglycomes fromdigital tool- ing, data governance, integrated report- ing ecosystems and AI-supported processes. These capabilities are becom- ingcritical tomanagingcomplexity, scal- ing operations, and maintaining a com- petitive edge in an evolving regulatory and investor environment. Fund landscape: ELTIFs and unregulated funds as the other growth leaders In the 2025Luxembourg fund landscape, UCITS remained the industry’s struc- tural anchor. AuM continued to grow, evenas the total number ofUCITS funds declined, a clear sign of ongoing consol- idation and rationalization of fund ranges across themarket. ELTIFssustainedtheirstrongmomentum, reaching157vehicles (9) (+64YoY).Theirex- pansion has rekindled interest in Part II UCIasapreferredwrapperforretailalter- nativestrategies,positioningLuxembourg as akeyhub for such typeof investments. At the same time, RAIFs continued to dominate the alternative space, surpass- ing3,200 (10) launchessinceinception.With 429 new structures in 2025, the second-best year after the 2022 peak, RAIFs are now used by 80% of ManCos having anAIFM license. (11) Their rise has directly accelerated the structural decline of SIFs and SICARs, as ManCos increas- ingly favorRAIFs for their speed-to-mar- ket and regulatory efficiency. However, CSSF Circular 25/901, which aimsataligningandrenderingmoreflex- ible the framework applicable to alterna- tive regulated products (notably Part II UCI, SIFs andSICARs), couldhelpdecel- erate this decline by restoring competi- tiveness and modern relevance to regulated wrappers. In addition, the structuralriseofprivatecredit,infrastruc- tureandrealassetsstrategiescontinuesto reshape demand for flexible structuring options, reinforcing Luxembourg’s lead- ership in alternative funddesign. The rise of newstrategies: a new strategic horizon for fundmanagers As Luxembourg’s ManCo landscape evolves, a newgenerationof investment strategies is rapidly emerging, changing investor expectations and accelerating regulatorymomentum. The retailization of alternatives is broadening the ad- dressable investor base, while ELTIF re- formanddistribution-driven innovation are lowering barriers between institu- tional and retail capital. At the same time, tokenization and crypto-related products are prompting fund managers to reassess product de- sign, custody models, and governance frameworks as regulatory clarity grad- ually improves. In parallel, the continued expansion of ETFs strategies is reinforcing the shift to- ward more scalable, transparent, and cost-efficient structures. Together, these developments are pushing ManCos be- yond traditional oversight roles and to- ward more technologically enabled, data-driven, and product-agnostic oper- atingmodels. Forfundmanagers,theabilitytocombine regulatory robustness with innovation, speed-to-market,andcross-assetexpertise is increasingly becoming a key differen- tiator inamore competitive and sophisti- cated European market. This evolution requiresanequallysignificanttalentshift, as firms increasingly depend on digital skills, alternative asset expertise, and strong product governance capabilities. Luxembourg at the heart of Europe’sManCo ecosystem Taken together, these developments highlight the remarkable dynamism of Luxembourg’s ManCo industry and its continued evolution into the strategic command center of European asset management. Despite intensifying reg- ulatory demands, technological disrup- tion, and margin pressure, the market has demonstrated strong adaptive ca- pacity combining consolidation with growth, scale with sophistication, and regulatory robustness with innovation. Luxembourg’s depth in cross border distribution, its predictable regulatory environment, and its rapid digital en- ablement further reinforces its role as Europe’s central platformformultijuris- dictional fund strategies. The riseofmulti-product platforms, inte- grated third-partyoperatingmodels, and new investment strategies underscores Luxembourg’s ability to centralize gov- ernance, expertise, and distribution for a rapidlydiversifyingEuropeanfundland- scape. As asset managers increasingly seek efficiency, speed-to-market, and cross-border reachunder a single regula- tory umbrella, Luxembourg is not only reinforcing its leadership position but also shaping the future operating model of the EU asset management industry. Pierre-MarieBOCHEREAU, Partner,Wealth&AssetManagement JensSCHMIDT, Partner,Wealth&AssetManagementConsultingLeader MadjidBOUKEHELIFA, Partner,Wealth&AssetManagementSectorLeader EYLuxembourg 1/2/3/4/5)CSSFStatistics 6/7/8) EY Luxembourg data based on a benchmarking research 9)ESMARegister 10/11LuxembourgBusinessRegister Inside Europe’s main ManCo landscape