ALFI responds to IESBA consultation CIV and pension funds

On 30 June 2025, ALFI responded to the International Ethics Standards Board for Accountants (IESBA) consultation, as we believe that the existing EU and Luxembourg frameworks already capture the relevant parties necessary to assess auditor independence in CIV and pension fund structures.

The framework defined in the IESBA Code is applied in conjunction with EU and national regulations under the supervision of the national competent authority (see further below regarding the CSSF). It enables a principles-based approach that allows auditors and national competent authorities to assess threats to independence in a manner that reflects the actual roles, influence, and risks posed by different parties within an investment fund structure.

ALFI believes that the existing framework, supported by European and national law, provides a well-calibrated and effective mechanism for managing auditor independence in the context of CIVs and pension funds. Efforts to refine or clarify guidance should allow for flexibility and recognize the diversity of investment fund structures, the functional roles of service providers, and the robust regulatory environment already in place in Luxembourg.

View the ALFI response.