Communication relative au rapport de la CSSF sur la revue thématique portant sur la valorisation des actifs moins liquides et illiquides (uniquement en anglais)

Over the past years, against the backdrop of successive crisis episodes, the global geopolitical and economic environment and the substantial increase of assets under management of AIFs investing in less liquid/illiquid assets, the CSSF has intensified its focus and scrutiny on valuation risks within the asset management sector.

Significant supervisory work, both off-site and on-site, has been carried out by the CSSF in that context (e.g. CSSF Feedback Report on the CSA, CSSF Feedback Report – Self-assessment questionnaire, separate report and management letter for funds, CSSF Annual Report 2024 sharing feedback from on-site controls).

In addition to the above, the CSSF launched at the end of 2023, by means of a dedicated questionnaire, an ad hoc thematic review (“Thematic Review”) with work carried out throughout 2024 and 2025 and focused primarily on valuation practices of AIFMs managing AIFs investing in less liquid/illiquid assets (e.g. private equity, real estate, infrastructure, private debt or fund of funds). On an ancillary basis, the review also dealt with valuation aspects/risks related to investments of UCITS under Article 41(2) of the UCI Law (i.e. the so-called “trash ratio” investments), notably unlisted securities or listed securities that are not actively traded.

The Thematic Review scrutinised more particularly some specific aspects/areas of the valuation policies and procedures of IFMs as well as the valuation controls in place during the life cycle of the investments.

The objective of this communication is to inform market participants about the publication of the CSSF Feedback Report “Thematic review – Valuation framework for less liquid and illiquid assets”. The Feedback Report provides IFMs, based on the applicable regulation, with guidance in relation to the implementation and maintenance of robust and appropriate valuation policies and procedures as well as valuation controls for the AIFs/UCITS they manage. It sets out, more particularly, a number of observations/recommendations which aim at harmonising and enhancing valuation practices of IFMs in certain areas. All IFMs are expected to carry out a benchmarking exercise against these observations/recommendations and, if applicable, to proceed in a next step to the necessary corrective measures.

Finally, considering the growth of AIFs investing in less liquid and illiquid assets, the increasing participation of retail investors in these funds, but also the current geopolitical uncertainties, valuation risk remains a key supervisory priority of the CSSF in 2026.