CSSF guidance on marketing communications

On 12 October 2022, the CSSF updated its FAQ on CBDF Marketing Communications ("CSSF FAQ"). The objective of this FAQ is to provide additional guidance to Luxembourg IFMs on certain key aspects of the marketing communication ("MC") requirements under Article 4 of the CBDF Regulation and ESMA Guidelines on marketing communications ("ESMA Guidelines"), which were implemented by the CSSF in its Circular 22/795.

The only change to the initial version of the FAQ in October is a change in the date from which IFMs must link marketing communications information to funds/sub-funds and identify ESG information (in the context of the application of Article 13 of SFDR and of the ESMA Supervisory briefing on Sustainability risks and disclosures in the area of investment management (ESMA34-45-1427)). This date has been changed from 1 April 2023 to 1 January 2023.

The key points of the CSSF FAQ, as amended in October 2022, are addressed in the dedicated  article on our website.