Upgrade and modernization of the Luxembourg fund product and manager laws

Luxembourg is once again showing its strength when it comes to adjusting to the evolution of the industry and responding to market demand. The upcoming changes to fund and manager laws are intended to make Luxembourg fund vehicles more attractive.

In the wake of the publication of Regulation (EU) 2023/606 on ELTIF v 2.0, the Luxembourg government has published, on 24 March 2023, the bill of law 8183 updating various laws relating to Luxembourg investment funds and their managers. This bill of law will, amongst other changes: 

• lower the thresholds of eligibility for « well-informed investors » under SICAR, SIF and RAIF laws from €125,000 down to €100,000;
• expand the ramp-up period for reaching the minimum capital amount (up to 24 months for SICAR, SIF and RAIF and up to 12 months for Part II funds);
• extend the legal forms available for Part II funds;
• allow AIFMs with a MIFID top-up licence to have recourse to tied agents (alignment with UCITS Chapter 15 Mancos); and
• expand the non-judicial liquidation regime of UCITS Mancos to AIFMs and AIF Chapter 16 Mancos. 

The bill of law will undergo the legislative process and we will provide you with a detailed overview in due course. 

Feel free to get in touch for more information.