Outlook 2025
ALFI’s Technical Committee Risk Management is the Center of Excellence for Luxembourg risk management professionals fostering an in-depth risk culture for members and the market overall.
Our mission
The Risk Management Technical Committee is a group of UCITS and AIF risk professionals that are open to and looking beyond the risk management community.
The Technical Committee is an active platform of experts supporting market participants being members of ALFI, irrespective of their nature and scale of operations and their various risk profiles, in measuring, assessing and managing the risks impacting Luxembourg Management Companies and the investment funds.
People who want to become risk management experts get an opportunity to contribute and increase their knowledge and competence for the benefit of the Luxembourg market place.
- Ambassador for Luxembourg’s well-established risk management community ensuring visibility within the global fund industry for Luxembourg’s subject matter expertise in risk management,
- Development of risk management industry standards and best practices based on expert discussions by industry professionals,
- Moderation of an industry voice when participating in risk management consultations issued by national and international bodies,
- Facilitate regular communication between professional market participants and act as a forum to establish and maintain an active Luxembourg risk management community,
- Maintaining working relations with regulators, other associations and groups involved in risk management,
- Oversee the creation and operation of risk management working groups and coordinate promotional and other lobbying activities,
- Coordination point for providing Risk Management subject matter experts’ input on other ALFI working groups/technical committees.
- Contribute to learning & development activities for risk management in collaboration with local organisations
News
AIFMD II/UCITS VI: Updating of Fund Documents for Liquidity Management Tools
The new liquidity management framework under AIFMD II and UCITS VI will come into effect on 16 April 2026. It will require funds to select at least two Liquidity Management Tools (LMTs), as defined in Annex V of the AIFMD or Annex IIA of the UCITS Directive, in both their prospectuses and instruments of incorporation or fund rules.
These requirements apply to all funds (UCITS and AIFs), including unregulated ones managed by an authorised AIFM. Closed-ended funds are, however, out of scope. Existing AIFs/UCITS must select at least two LMTs and include them in their instruments of incorporation or fund rules by 16 April 2026. These changes must be approved by the CSSF. However, if the instruments of incorporation or fund rules already contain information clearly specifying the selected LMTs, there is no need to update them. It is worth noting that a general reference to all tools in the relevant annex is sufficient as long as the Prospectus clearly specifies which tools have been selected. Updating instruments of incorporation or fund rules across fund ranges requires time and resources. Therefore, managers are recommended to begin this process promptly. Any specific challenges can be discussed with the regulator on a case-by-case basis.
By 16 April 2026, prospectuses must detail which LMTs apply to the relevant funds, sub-funds and investment strategies. These changes do not require prior approval from the CSSF and can be made via eDesk. However, existing funds will have the option, but not the obligation, to continue applying their current policies and procedures to LMTs until 16 April 2027. During this period, they will not be subject to the Commission Delegated Regulations laying down regulatory technical standards specifying the characteristics of LMTs.
The selected LMTs will also have to communicated to the CSSF in line with Article 20a of the UCITS Directive and Article 16 of the AIFMD. The CSSF is developing a digital solution via e-Desk for this reporting and we will communicate more information in due time.