Published on 18 September 2026
Communiqué

Communication to the Investment Fund Industry regarding the requirement to notify the “suspension of redemption (only)” in the “LMT activation” module related to liquidity management requirements

for Luxembourg-domiciled funds subject to the 2010 Law relating to UCIs, specialised investment funds governed by the Law of 13 February 2007, and investment companies in risk capital governed by the Law of 15 June 2004.

This communiqué follows up on the CSSF Communiqué published on 10 April 2026 detailing the implementation of the “LMT activation” module for notifications of LMT activation and deactivation, as introduced by the liquidity management requirements for funds subject to the Law of 3 March 2026 (the “2026 Law”), transposing Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024. The CSSF hereby informs market participants about the extension of the “Liquidity Management Tool (LMT) eDesk procedure” to include, within the “LMT activation” module, the activation and deactivation of suspensions of redemptions (only) under national law provisions applicable to:

  • Luxembourg-domiciled funds subject to the Law of 17 December 2010 relating to UCIs (the “2010 Law”);
  • specialised investment funds governed by the Law of 13 February 2007 (the “2007 Law”); and
  • investment companies in risk capital governed by the Law of 15 June 2004 (the “2004 Law”).

This update aligns with the ongoing efforts of the CSSF to facilitate and streamline administrative processes for financial market participants. The suspension of redemptions only (without suspension of subscriptions) does not qualify as an LMT under the 2026 Law but is integrated into the “LMT activation” module to simplify notification procedures for market participants. The activation and deactivation of a suspension of redemptions must be notified as from 21 September 2026 through the eDesk “LMT activation” module. However, the administrative requirements, including the submission of supporting documentation, remain unchanged and must continue to be submitted to the CSSF through the usual communication channels.

The CSSF reminds Luxembourg-domiciled funds subject to Part II of the 2010 Law that are not managed by a Luxembourg-domiciled authorised AIFM, that they must also notify the CSSF of the activation or deactivation of suspensions of subscriptions, repurchases and redemptions, as well as the creation of side pockets previously approved by the CSSF under the “LMT activation” module, as required under the respective sectoral laws. The same applies to Luxembourg-domiciled funds subject to the 2007 Law and the 2004 Law, which do not qualify as AIFs or are not managed by a Luxembourg-domiciled authorised AIFM.

In addition, the CSSF reiterates the requirements under the 2026 Law to select, activate, and deactivate LMTs through the eDesk procedure. The CSSF wishes to emphasise that existing sub-funds, as from 16 April 2026, as well as new sub-funds, as from the date of their establishment, must comply with these requirements. Further information on the “LMT selection” module is available in the CSSF Communiqué of 18 March 2026, while additional details on the “LMT activation” module can be found in the CSSF Communiqué of 10 April 2026.