Non-regulated AIFs: New reporting obligations

The Central Bank of Luxembourg (Banque Centrale de Luxembourg, “BCL”) issued a circular on 18 May 2018 (BCL 2018/241) requiring non-regulated AIFs to report information to the BCL upon incorporation, and periodically, on a monthly, quarterly or annual basis. The periodicity of the reporting is determined on the basis of the size of the AIF and the threshold under which the BCL may grant an exemption to provide a monthly or a quarterly reporting is fixed at EUR 500 million of total assets. In this latter case, only an annual reporting is due.

A calendar of remittance dates on which the reports are due is published on the BCL website, however, the implementation of the new collection consisted of  a two-step process:

• For existing non-regulated AIFs as at the date of the BCL circular, the duly completed BCL form (available on its website) and the latest available balance sheet had to be sent by mail to the BCL by 31 may 2018.
• For non-regulated AIFs which are not exempted from the monthly and quarterly reporting, (i) the next quarterly reporting and the monthly report for the September 2018 reference period must be submitted before 26 October 2018, and (ii) the monthly report for the October 2018 reference period must be submitted before 29 November 2018.