Important principles governing the authorisation procedure for investment firms


    General principles

    • A complete application file based on the Application form for authorisation as investment firm and an inventory (containing further information in addition to the form) must be submitted to the CSSF in electronic form to the email address
    • Only the official documents (declaration of honour, extract from the criminal record, etc.) must be submitted in paper format to the CSSF. Please note that these documents must not be older than three months.
    • The application file must contain all the information necessary for its assessment, which will be based on the form as well as the substance of the information provided.
    • The applicant must ensure to diligently respond to any request for additional information and provide the supporting documents.
    • Prior to sending the file, an MFT link should be requested via the aforementioned email address, in order to ensure a secure electronic transmission of data.

    Indicative list of the key information to be provided

    Please find below a non-exhaustive list of the key information to be provided:

    Basic information

    • Presentation of the future investment firm (including the articles of incorporation);
    • Presentation of the project (including the rationale for the creation of an investment firm and establishment in Luxembourg).

    Description of the business model

    • Detailed description of the MiFID activities and services proposed;
    • Indication of any other envisaged service or activity;
    • Description of the targeted clients;
    • Detailed description of the commercial strategy including, in particular, the geographical distribution of the services/products (indication of the countries in which the provision of services notably via free provision of services is envisaged and of the activities and products to be offered in this way) and of the envisaged branches/subsidiaries/tied agents;
    • Description of other key elements of the business model (notably the use of innovating technologies, use of intragroup transactions);
    • Use or not of omnibus accounts and strategy in terms of determination of depositary bank(s);
    • Financial projections for the first three years of activity (balance sheet, profit and loss account, fee and commission income, etc.);
    • Audited financial statements of the last three years (where the entity already exists);
    • Description of the business continuity plan (BCP), including the backup facilities & disaster recovery plan (description of the stages, procedures and tasks to perform at the occurrence of a disaster, the implementation of backup/fall-back solutions allowing restoring of the environment and continuing activities on a going concern basis).

    Central administration/internal governance

    • Internal organisation chart of the future investment firm (including the board of directors, authorised management, committees of the board of directors, operational committees, key functions, operational and administrative departments, etc.), including the hierarchical and functional structures;
    • Description of internal governance, including the key processes, conflict of interest policy and AML/CFT policy;
    • Information regarding the internal control functions (organisation, persons in charge of the function, hierarchical structure);
    • Presentation of the members of the board, of the authorised management and of the key function holders;
    • Details regarding the client asset safekeeping and protection;
    • Description of the organisational structure, including human resources;
    • Description of the IT infrastructure and organisation;
    • Description of outsourcing arrangements.


    • Presentation of the group, including the full organisation chart detailing all the group companies supervised by a supervisory authority;
    • Description of the direct and indirect shareholders (identity, details of the shareholders’ rights, shareholder agreement, extract from the register of shareholders);
    • Presentation of the ultimate beneficial owners (identity, fit and proper, proof of financial soundness) having a qualifying holding (10% or more of the share capital or the voting rights of the investment firm or in case of significant influence).

    Own funds and liquidity requirements

    • Own funds (amount, own funds instruments and prudential eligibility) and projected own funds ratio;
    • Liquidity (composition of liquid assets) and projected liquidity ratio.