CSSF and AED AML/CFT questionnaires and other AML/CFT reporting taking place in 2026 for CSSF supervised entities and AED supervised RAIFs

1. CSSF supervised entities

The Commission de surveillance du secteur financier (“CSSF”) has confirmed the launch of its AML/CFT data collection exercise through relevant questionnaires for the year 2025 (via Circular letter dated 12 February 2026 - the “CSSF 2026 Circular”).

Based on the CSSF 2026 Circular, a distinction is made between three groups of supervised entities:

(i) Group A – Supervised entities selected to participate in the AMLA “calibration exercise”

Some CSSF supervised entities (including certain AIFMs and UCITS ManCos) have been selected by the European Authority for Anti-Money Laundering and Countering the Financing of Terrorism (“AMLA”) (and already notified by the CSSF) to take part in AMLA’s data collection exercise for 2026 to test risk assessment models for the financial sector (“AMLA AML/CFT Exercise”). In this context, the selected entities will have to complete the new AMLA prepared questionnaire template (the “AMLA AML/CFT Questionnaire”) for the year 2025, instead of the CSSF AML/CFT questionnaire template. 

This data collection exercise will launch on 2 March 2026 and shall be reported to the CSSF by 15 April 2026 via the eDesk platform. The definitive template and an interpretative guidance in this respect will be made available soon by AMLA.

(ii) Group B – Supervised entities not selected to participate in the AMLA AML/CFT Exercise (other than specialised PFS)

CSSF supervised entities other than specialised professionals of the financial sector (“PFS”) that were previously subject to the obligation to submit the CSSF AML/CFT Questionnaire (i.e. notably AIFMs, including registered AIFMs, and UCITS ManCos) and that have not been selected to participate in the AMLA AML/CFT Exercise (i.e. Group A entities) will now also have to complete the AMLA AML/CFT Questionnaire for the year 2025 instead of the CSSF AML/CFT questionnaire.

This new AMLA AML/CFT Questionnaire will also launch on 2 March 2026 via the eDesk platform and further modalities and reporting timelines will be communicated shortly by the CSSF.

(iii) Group C - Specialised PFS

All specialised PFS that are out of scope of the AMLA AML/CFT Exercise are invited to complete the annual AML/CFT questionnaire based on the CSSF template.

The CSSF AML/CFT questionnaire will also launch on 23 February 2026 via the eDesk platform, and responses shall be submitted by 3 April 2026 for specialised PFS.

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For the avoidance of doubt, the so-called annual “RC report” will remain a separate process, which still has to be completed and filed by in-scope CSSF supervised entities in due course with the CSSF (i.e. within five months after the closing of the annual accounts of the supervised entity). 

2. AED supervised AIFs

(i) Reserved alternative investment funds (“RAIFs”)

The Administration de l’Enregistrement, des Domaines et de la TVA (“AED”) has updated its website to confirm the reporting deadline of the relevant AML/CFT documentation for RAIFs covering the year 2025, as follows:

• the AML/CFT Questionnaire covering the year 2025 shall be submitted by 31 May 2026. Further indications and guidance may be found on the relevant section of the AED website;
• the annual RC report for RAIFs filed shall also be filed with the AED by 31 May 2026 COB with data as at 31 December 2025. Reference is also made to the dedicated section of the AED website.

(ii) Non-regulated AIFs other than RAIFs

Lastly, and as announced in our previous newsflash on AML/CFT for RAIFs and other non-regulated alternative investment funds (“AIFs”), the submission of the AML/CFT questionnaire and the RC report covering the year 2025 for non-regulated AIFs other than RAIFs will be limited to those AIFs having received an invitation to this end from the AED.

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Should you wish to receive more information in respect of the above, please feel free to reach out to your usual contact persons at Elvinger Hoss Prussen.