Luxembourg: Fast-Track For Sustainability-Related Disclosures

In relation to funds, the Sustainable Finance Disclosure Regulation imposes an obligation on EU AIFMs and UCITS management companies to include disclosures in the offering documents for the funds they manage. In Luxembourg, the Financial Sector Supervisory Commission (CSSF) has provided for a fast-track procedure regarding SFDR disclosures, to avoid backlogs.

The offering documents of regulated funds which include these disclosures will be filed directly for a visa. In practice, this means that funds will be able to file their offering documents without going through the usual regulatory approval process, providing the CSSF with a self-certification form that the CSSF will review in a reduced timeframe. The CSSF expects the filings of documents to be made before 28 February 2021. Such offering documents will only be rejected in exceptional circumstances.