Reform of Circular CSSF 22/811 – Changes relating to the annual reporting to be submitted by UCI administrators

This communiqué is a follow-up to the CSSF communiqué published on 30 June 2023 relating to the new reporting module for the annual reporting to be submitted by UCI administrators (UCIAs) pursuant to point 7 of Circular CSSF 22/811 (the “UCIA Circular”).

The purpose of this communiqué is to inform market participants of changes relating to this annual reporting, as described below, as well as the publication of Circular CSSF 25/900, which amends Circular CSSF 22/811 in this context.

To be noted that these changes are effective as of 31 December 2025 (the “Effective Date”).

The revised reporting framework introduces a new self-assessment questionnaire (SAQ) that will focus on key requirements resulting from the UCIA Circular. In parallel, the scope of information to be reported on UCIAs’ business activities and resources has been significantly reduced.

UCIAs whose financial year ends on or after the Effective Date will need to report using this revised reporting framework.

In addition to these changes, it is important to note the following points:

a) For credit institutions, investment fund managers, support professionals of the financial sector and investment firms authorised as registrar, client communication or administrative agents acting as UCIAs: The UCIA reporting will be integrated into the annual long form reports (LFRs) or SAQs to be provided under Circulars CSSF 22/821, 23/839, 24/850 and 25/870. As a result, no separate reporting will be required for these entities.

b) For specialised professionals of the financial sector acting as UCIAs: The UCIA reporting will be accessible via the annual Specialised PFS SAQs (the “PFS-SP SAQ”) on the CSSF eDesk platform. The PFS-SP SAQ will comprise: (i) a dedicated section for registrar, administrative and client communication agents acting as UCIAs within the meaning of the UCIA Circular; and (ii) a dedicated section for professional depositaries of assets other than financial instruments (PDAOFIs) for Luxembourg-domiciled UCIs, depending on the relevant PFS licence. The deadline to submit the report will be three months starting as from the Effective Date.

c) For all other entities acting as UCIAs: The “UCI Administrator Reporting Tool” (the “UCIAR procedure”) will remain accessible on the CSSF eDesk platform for submitting their annual reports. These entities may also submit this report via an API solution (S3 protocol), enabling automated data flow. A user guide, available within the eDesk procedure, will provide details on the reporting submission process. For these entities, the deadline to submit the UCIA report will remain at the latest five months after the UCIA’s financial year-end, starting from the Effective Date.

Due to the above changes, the UCIA Circular has been amended by Circular CSSF 25/900.

This circular is applicable from the Effective Date.

Annex B of the UCIA Circular, which detailed the information regarding UCIAs’ business activities and resources to be provided to the CSSF on an annual basis until the Effective Date, has been repealed. Similarly, the reference to the deadline to submit the annual reporting has been deleted, as this date will now vary depending on the entity type (see point 2 above).

Information on modalities and instructions for the submission of the revised annual reporting for UCIAs, including user guides, where applicable, will be available on the CSSF website.

Furthermore, given the entry into application of the DORA regulation in January 2025, and the subsequent changes to numerous CSSF circulars in relation to this, the UCIA Circular has also been amended in this regard.

For any questions regarding the changes relating to the UCIA reporting, please contact: uciar@cssf.lu or the dedicated supervisory departments.