Update of CSSF FAQ on UCITS

On 17 February 2026, the Commission de Surveillance du Secteur Financier (“CSSF“) published an updated version of its FAQ on the law of 17 December 2010 relating to undertakings for collective investment, which includes the following clarifications on the holding of ancillary liquid assets by UCITS and on the public disclosures of portfolio holdings of UCITS ETFs:

• Holding of ancillary liquid assets by UCITS – The  CSSF FAQ clarifies that UCITS may also hold e-money tokens as defined in MiCAR (Regulation 2023/1114), provided that this is made for the sole purpose of processing subscriptions or redemptions and that such e-money tokens are converted to bank deposits at sight or invested in eligible assets as soon as practicable. UCITS are expected to comply with the conditions applicable to the holding of ancillary liquid assets as described in the CSSF FAQ in relation to e-money tokens converted into bank deposits at sight. 
• Disclosures of portfolio holdings of UCITS ETFs – The CSSF FAQ is amended to clarify that the specific guidance it provides on portfolio transparency requirements also extend and apply to all UCITS ETFs and no longer specifically to actively managed UCITS ETFs only. Moreover, in the future, UCITS ETFs will be able to disclose their full portfolio holdings to all investors on a quarterly basis with a maximum time lag of 30 business days (while the previous version of the CSSF FAQ required active UCITS ETFs to publish such information on a monthly basis).

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.