Lancement de l’action de surveillance commune de l’ESMA sur la fonction de gestion des risques des sociétés de gestion d’OPCVM et des gestionnaires de fonds d’investissement alternatifs (uniquement en anglais)

On 3 July 2026, the European Securities and Markets Authority (ESMA) launched a Common Supervisory Action (CSA) with National Competent Authorities (NCAs) on the risk management function of UCITS Management Companies and authorised Alternative Investment Fund Managers (“IFMs”) across the European Union.

The methodology used for this CSA was developed by ESMA, in collaboration with NCAs, with the objective of ensuring a common supervisory approach across NCAs.

The aim of the CSA is to investigate to what extent IFMs have established an effective and independent risk management function with adequate staffing, authority, knowledge and expertise to perform their duties under the UCITS and AIFMD frameworks. The risk management function, which is a core function in the context of investor protection and financial stability, must ensure that material risks, such as market, credit, liquidity, counterparty, sustainability and operational risks, are properly identified, measured, monitored and managed. As such, it is essential that IFMs have in place a robust risk management framework.

In this context, on 27 July 2026, the CSSF launched the CSA by asking a sample of Luxembourg-based IFMs to complete a questionnaire, with a focus on (i) the governance and organisation of the risk management function, (ii) the identification, measurement and monitoring of risks and (iii) the reporting to senior management and governing bodies.

All concerned Luxembourg-based IFMs were contacted by the CSSF by email in that context. The IFMs that have not received an email from the CSSF on this subject matter are not concerned by this CSA exercise. In this regard, the CSSF reminds IFMs that they must keep the email addresses of eDesk users and their corresponding roles up to date, so that specific communications reach the relevant persons.

In order to benefit from a secure exchange platform and pre-submission data quality checks, the response questionnaire will have to be submitted by the Luxembourg-based IFMs through the CSSF’s eDesk Portal. The entities in scope of the CSA will be duly informed once this section becomes available for use.