Luxembourg law implementing AIFMD II adopted

Luxembourg has just completed the transposition of Directive (EU) 2024/927 (“AIFMD II”), which amends the AIFM and the UCITS Directives.

The newly adopted law introduces changes to:

• The Law of 17 December 2010 on undertakings for collective investment (“UCI Law”)
• The Law of 12 July 2013 on alternative investment fund managers (“AIFM Law”)

The publication on 9 March 2026 of the UCI Law and of the AIFM Law as amended by AIFMD II (together the “New AIFM and UCI Laws”) well ahead of the transposition deadline set by the Directive (i.e. 16 April 2026) enables the industry to anticipate changes and be ready for the new regime.

It is also important to note that the implementing approach of AIFMD II in the New AIFM and UCI Laws is to reflect the provisions of the Directive “as is”, without gold plating. 

AIFMD II’s key areas

The key areas addressed by AIFMD II include, among other things, delegation arrangements, liquidity risk management, supervisory reporting, depositary, white-labelling and harmonised rules for loan origination. 

It also expands the range of permitted services and functions for AIFMs and UCITS management companies (“UCITS ManCos”), such as credit servicing (relevant for AIFMs), and benchmark administration (relevant for AIFMs and UCITS ManCos). In addition, AIFMs and UCITS ManCos will be authorised to perform, as an ancillary service for third parties, the same functions and activities that they already perform in relation to the funds they manage, if they have an adequate framework for managing conflicts of interest.

For more information on this last point and the options offered by AIFMD II and implemented in Luxembourg, see our previous newsflash (here).

The New AIFM and UCITS Laws are also available in French and in English in our new brochures:

• The amended Law of 12 July 2013 on alternative investment fund managers
• The amended Law of 17 December 2010 on undertakings for collective investment

Next Steps 

The New AIFM and UCI Laws will become applicable on 16 April 2026.

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 or the authors of this article mentioned below.