On 18 May 2018, the Luxembourg Central Bank (BCL) issued Circular 2018/241, which reminds the market about the statistical data collection for non-regulated alternative investment funds (AIFs).

Circular BCL 2018/241 (available in English and French) reminds non-regulated AIFs of their reporting obligations under the European Central Bank's (ECB) regulation 2013/38 concerning statistics on the assets and liabilities of investment funds and the ECB guideline on monetary and financial statistics. It defines the content, delays and reporting formalities.

Information to be submitted

In order to complete the identifying data of non-regulated AIFs, the AIFs must provide the BCL with additional data within a week of the first day of their activities, regardless of whether or not they expect to be subject to the reporting requirements.

In accordance with the ECB's regulation 2013/38, AIFs need to submit the following reports to the BCL:

  • Information on valuation effects on the balance sheet of non-MMF investment funds (Template S1.6)
  • Monthly security-by-security report of investment funds
  • Quarterly statistical balance sheet for non-MMF investment funds (Template S2.13)

Formalities of transmission

The new statistics collection will be implemented in two phases:

  1. Prior to 31 May 2018: The transmission of the completed form regarding the identifying data (available on the BCL's website), and of the latest available balance sheet
  2. For non-exempted AIFs:

    1. Prior to 26 October 2018: The transmission of the quarterly statistical balance sheet for non-MMF investment funds and of the monthly security-by-security report for September 2018
    2. Prior to 29 November 2018: If applicable, the monthly information on valuation effects on the balance sheet of non-MMF investment funds for the October 2018 reference period.

The instructions for the statistical reporting can be downloaded from the BCL's website under "Regulatory reporting".


The BCL may grant derogation from monthly and quarterly reporting to non-regulated AIFs with aggregate assets (including compartments) below €500 million (BCL may change by circular letter).

The exempt AIFs must only submit their annual accounts to the BCL within 15 days after their certification.


In case of non-compliance, the ECB has the power to impose sanctions following an infringement procedure.

Action points

If you are a professional that is affected by Circular BCL 2018/241, you should ensure that all necessary information is submitted to the BCL by the required deadlines.

Our team can assist you if you need more information about the new circular.

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