Communication on the CSSF Feedback Report – Circular CSSF 24/856

Circular CSSF 24/856 on the protection of investors in case of an NAV calculation error, an instance of non-compliance with the investment rules and other errors at UCI level (the “Circular”) entered into application on 1 January 2025, repealing on that date Circular CSSF 02/77.

In parallel to the entry into force of the Circular, the CSSF has adapted the notification forms by aligning them with the new guidelines of the Circular and has introduced, in that context, a secure transmission channel for the notification forms via the eDesk platform or alternatively via automated submission via API (S3 protocol). A user guide titled “UCI notification in accordance with Circular CSSF 24/856 – Practical and technical guidance” has been published in that context to inform entities about the transmission of notifications to the CSSF under the Circular.

The objective of this communication is to inform market participants about the publication of the CSSF Feedback Report “Circular CSSF 24/856”.

Against the backdrop of the experience gathered by the CSSF with the new framework over the year 2025, this feedback report presents, first, statistics on the notifications submitted to the CSSF under the Circular. It then sets forth – based on the notifications received – observations that the CSSF made for the different errors/instances of non-compliance in scope of the Circular, before sharing its experience with the updated notification forms integrated into the eDesk platform. On that basis, the report also draws the attention of the industry to a number of observations made by the CSSF which the industry should duly consider when notifying the CSSF.

All entities within the scope of Circular CSSF 24/856 are expected to give due consideration to the observations set out in the CSSF Feedback Report when preparing and submitting notifications to the CSSF.