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Annual AML/CFT reporting for Luxembourg funds: the five deliverables, the 2027 calendar and who files

By the RC Insight team, practitioners who have helped more than 80 fund promoters set up their AML/CFT framework since 2020.

Published Last reviewed: 14 min read

Annual AML/CFT reporting for Luxembourg funds rests on five deliverables: the SRRC, the RC's summary report to the board, the 21/788 external report, the CSSF annual data collection and the AED questionnaire with its RC report. Which ones an entity prepares or files depends on its type and its supervisor, the CSSF or the AED.

This guide to annual AML/CFT reporting for Luxembourg funds maps each deliverable to each entity type, sets out the coming season's calendar by year-end and shows who prepares and who files each report. For the wider picture, start from our guide to AML/CFT for Luxembourg investment funds; for the supervisor question, read CSSF or AED: who supervises your fund.

Key takeaways

  • Annual AML/CFT reporting for Luxembourg funds rests on five deliverables; which ones an entity prepares or files depends on its type and its supervisor, the CSSF or the AED.
  • The SRRC is due within five months after the closing of the annual accounts: 31 May 2027 for a 31 December 2026 year-end, 30 November 2027 for a 30 June 2027 year-end.
  • For RAIFs, the AED deadline for reference year 2026 is expected to be 31 May 2027, a date the AED confirms each year.
  • The RC prepares the SRRC and the RR submits it; in our practice, every communication with the supervisors stays under the RR's responsibility.
  • For its 2026 campaign, the CSSF used AMLA data-collection templates instead of its usual Questionnaire on Financial Crime; the 2027 modalities are not yet published.
On this page
  1. The five annual AML/CFT deliverables in one table
  2. Which AML/CFT reports a Luxembourg fund files, by entity type
  3. The 2027 AML/CFT reporting calendar for Luxembourg funds, by year-end
  4. Who prepares and who files each AML/CFT report
  5. The deliverables one by one
  6. What changed in 2026
  7. Preparing the 2027 reporting season
  8. How RC Insight helps
  9. FAQ
  10. Sources

The five annual AML/CFT deliverables in one table

Five recurring deliverables make up the annual AML/CFT reporting of Luxembourg funds and their managers, each with its own legal basis and deadline or frequency rule.

  • SRRC (AML/CFT Summary Report RC): the CSSF summary report governed by Circular 24/854 of 29 February 2024, due within five months after the closing of the annual accounts and submitted exclusively via eDesk.
  • The RC's summary report to the board: under Article 42(6) of CSSF Regulation 12-02, at least once a year, the RC prepares a summary report on its activities and operation and submits it to the RR, the authorised management and the board.
  • The 21/788 external report: the annual AML/CFT external report prepared by the réviseur d'entreprises agréé under CSSF Circular 21/788, due within six months after year-end via eDesk.
  • The CSSF annual data collection: for the 2026 campaign, the CSSF used AMLA data-collection templates, filed on eDesk by the RC or the RR, instead of its usual Questionnaire on Financial Crime; the 2027 modalities are not yet published.
  • The AED questionnaire and RC report: for RAIFs, an Excel AML/CFT questionnaire with data as at 31 December and a signed PDF RC report, due by 31 May, a date the AED confirms each year. Other unregulated AIFs filed them only on AED invitation in 2026.

The table shows which entity type prepares or files what.

Entity type SRRC RC summary report to the board 21/788 external report CSSF data collection AED questionnaire and RC report
Luxembourg IFM, including a registered AIFM Yes, its own Yes, at least once a year Yes Yes, a 2026 addressee No: supervised by the CSSF
CSSF-supervised fund with a Luxembourg IFM No: the Luxembourg IFM files Yes, for the RR and the board; the CSSF may request it No: exempt under section 1.2 No: not a 2026 addressee No
Self-managed CSSF-supervised fund Yes, its own Yes, at least once a year Yes Yes, a 2026 addressee No
CSSF-supervised fund with a foreign IFM Yes: the fund files, not its foreign IFM Yes, at least once a year No: exempt In our practice, not filed in 2026 No
RAIF No: supervised by the AED In our practice, the AED RC report with the risk assessment attached No: supervised by the AED No: supervised by the AED Yes; deadline expected to be 31 May 2027, a date the AED confirms each year
Other unregulated AIF, such as an unregulated SCSp No: supervised by the AED In our practice, the same standard as for a RAIF No: supervised by the AED No: supervised by the AED In 2026, on AED invitation only

A RAIF is supervised by the AED for AML/CFT even when its AIFM is CSSF-authorised: the AIFM is supervised by the CSSF, the RAIF by the AED. For an entity that files the SRRC, the SRRC is the form in which the Article 42(6) report reaches the CSSF, under Article 42(7).

Which "annual RC report"?

The phrase "annual RC report" covers several different documents, so check which document a request refers to before you start. For a CSSF-supervised entity that files its own report, it is the SRRC, which replaced the former annual RC report for the collective investment sector (our SRRC guide). For a RAIF or another AIF supervised by the AED, it is the signed RC report sent to the AED (AED RC report for RAIFs). For every CSSF-supervised entity, it is also the summary report the RC prepares at least once a year for the RR, the authorised management and the board (the RC's annual report to the board).

Which AML/CFT reports a Luxembourg fund files, by entity type

Your supervisor decides the family of deliverables, and your management set-up decides who files them. For CSSF-supervised funds, the matrix above answers by management set-up; the notes below cover IFMs and the AED side.

Luxembourg IFMs, including registered AIFMs

The CSSF supervises for AML/CFT all Luxembourg IFMs: UCITS management companies, authorised AIFMs and registered AIFMs. A Luxembourg IFM files its own SRRC and its 21/788 external report, and was an addressee of the 2026 CSSF data collection. Registered AIFMs are expressly named in the scope of the SRRC and among the addressees of the 2026 data collection. If you run compliance at an AIFM or a management company, see RC Insight for AIFMs and management companies.

RAIFs

A RAIF files the annual AED AML/CFT questionnaire (Excel, data as at 31 December) and the annual RC report (signed PDF) with aed.raif@en.etat.lu. For reference year 2026, the deadline is expected to be 31 May 2027, a date the AED confirms each year. The AED states that the AIFM's compliance never exempts a RAIF from its own AML/CFT obligations.

Other unregulated AIFs

The AED also supervises Luxembourg AIFs not prudentially supervised by the CSSF, such as unregulated SCSp, SCS or SCA AIFs. In 2026, their questionnaire and RC report (data at 31 December 2025) were filed only on AED invitation, to aed.aif@en.etat.lu. The absence of an invitation does not exempt a fund from its legal obligations.

The 2027 AML/CFT reporting calendar for Luxembourg funds, by year-end

The SRRC and the 21/788 external report run from the entity's financial year-end, while the AED campaign and the CSSF data collection follow the calendar year. The SRRC is not a fixed calendar date: it is due within five months after the closing of the annual accounts (31 May only for a 31 December year-end).

Financial year-end SRRC, within five months (eDesk) 21/788 external report, within six months (eDesk)
31/12/2026 31 May 2027 30 June 2027
31/03/2027 31 August 2027 30 September 2027
30/06/2027 30 November 2027 30 December 2027
30/09/2027 29 February 2028 30 March 2028

Each 21/788 date above falls six months after the financial year-end, the period set by Circular 21/788.

The AED and CSSF exercises follow the calendar year.

Calendar-year exercise Data covered Date for the 2027 campaign
AED questionnaire and RC report, RAIFs Data as at 31 December 2026 Expected to be 31 May 2027, a date the AED confirms each year
AED questionnaire and RC report, other AIFs In 2026: data at 31 December 2025 2027: not announced. In 2026, filed only on AED invitation
CSSF annual data collection Not yet published (2026 campaign: reference year 2025, AMLA templates) Not yet published; the 2026 deadlines were 22 April and 22 May 2026

To compute the dates for another year-end, use the AML/CFT deadline calculator; to keep them in your agenda, use the AML/CFT calendar for Luxembourg funds.

Who prepares and who files each AML/CFT report

The RC prepares the SRRC and the AED RC report; the RR submits the SRRC and transmits the AED questionnaire, and may mandate the RC to transmit it. The 21/788 report is submitted by the RC, the RR or a board member, under the board's responsibility. In our practice, every communication with the supervisors stays under the RR's responsibility; the RR may mandate the RC to send it.

Deliverable Prepared by Submitted by Channel
SRRC The RC The RR, who remains accountable even if the technical submission is delegated eDesk only
Article 42(6) summary report The RC The RC submits it to the RR, the authorised management and the board Internal for a CSSF-supervised fund with a Luxembourg IFM: not sent automatically, may be requested; for an entity in the SRRC scope, it reaches the CSSF as the SRRC
21/788 external report The réviseur d'entreprises agréé that audits the annual accounts, or one mandated for this purpose where no audit is legally required The RC, the RR or a board member, under the board's responsibility eDesk only
CSSF data collection In our view, the RC should coordinate the data The RC or the RR (2026 campaign) eDesk (2026 campaign)
AED questionnaire (RAIFs) The RR or the RC, or a person they have officially mandated The RR, who may mandate the RC, in a separate e-mail with no other file attached aed.raif@en.etat.lu
AED RC report The RC: a summary report on its AML/CFT activities and operation at the fund The AED addresses its invitation to the RC; in our practice, the filing stays under the RR's responsibility A single signed PDF by e-mail; a scanned PDF is not accepted

CSSF Regulation 12-02 does not require the board to approve the RC's summary report, but the SRRC asks for confirmation that the findings contained in the report have been presented to and acknowledged by the board. We recommend fixing that board meeting well ahead of the SRRC deadline.

The deliverables one by one

Each deliverable has its own guide; the summaries below give the essentials and the link.

SRRC: the CSSF summary report

The SRRC is filed on eDesk either through the online form or as a zipped JSON file, and can be corrected and resubmitted until the five-month deadline; only the last submission counts. Its template has 15 sections, including a Risk Assessment section on a four-level scale and an AML/CFT Findings register. The annual ML/TF risk assessment no longer has to be filed with the SRRC, but it must still be performed and documented. The SRRC FAQ version 3 and the user guide version 1.0 were still the current versions on 4 October 2026. The full walkthrough is in our SRRC guide (CSSF Circular 24/854), and you can test your preparation with the SRRC readiness check.

The RC's annual report to the board

Article 42(6) of CSSF Regulation 12-02 requires the RC to prepare, at least once a year, a summary report on its activities and operation, and lists no headings for it. Article 42(5) adds regular written reports covering the follow-up of past recommendations, new problems and shortcomings, the related risks and the corrective measures proposed. In its 2022 sub-sector risk assessment, the CSSF recommended that entities outside the scope of Circular 18/698 consider its requirements as best practice. In our practice, we apply the same standard to RAIFs and other AIFs supervised by the AED. Structure, content and board presentation are covered in the RC's annual report to the board.

The 21/788 external report

An entity that must appoint a réviseur d'entreprises agréé to audit its annual accounts appoints the same réviseur to prepare the external report; an entity without that legal requirement mandates one for this purpose. The réviseur answers questions that are in principle closed and do not result in an audit opinion. The report has a section corroborating the entity's answers to the CSSF annual online survey and a section on sample testing or specific work. In our practice, the corroboration section was not performed in 2026, because the CSSF had replaced its Financial Crime Questionnaire with the AMLA templates that year. Scope, exemptions and the RC's role are detailed in CSSF Circular 21/788: the AML/CFT external report.

The CSSF annual data collection

The data collection is a separate exercise from the SRRC, which is a summary report and not a questionnaire. For the 2026 campaign, the CSSF replaced its annual Questionnaire on Financial Crime with AMLA data-collection templates, filed on eDesk by the RC or the RR. The 2027 modalities are not yet published, and dates change every year: always check the CSSF circular letter. Addressees and templates are explained in the CSSF annual AML/CFT data collection.

The AED questionnaire and RC report for RAIFs

The RC report covers at least twelve topics, from the fund's exact name and RCS number to the number of breaches identified, with zero stated explicitly. The questionnaire is kept in its original Excel format and sent in a separate e-mail with a set file name; a questionnaire that does not follow the AED guide is sent back. In its RAIF section, the AED's January 2026 newsletter reported generally late transmission of the 2024 questionnaires and RC reports, and recurring RC-report errors: a missing signature, a wrong or missing RCS number and a non-compliant file name. Separately, it stated that 768 of the 2,389 RAIF RC reports filed for 2024 were rejected; it does not say that the listed errors caused these rejections. The topic-by-topic checklist is in AED RC report and questionnaire for RAIFs.

AED reporting for other unregulated AIFs

The AED supervises these AIFs for AML/CFT and runs reporting campaigns for them, with a questionnaire and an RC report. In 2026, their RC report covered the same twelve topics as for RAIFs, and their questionnaire was transmitted by the RR, who may mandate the RC. In our practice, for an SCSp, the RR sits at general partner level; where the general partner is also the fund's registered (de minimis) AIFM, an RC is appointed at both levels. What to prepare without waiting for an invitation is set out in AED AML reporting for unregulated AIFs.

Missed filings and sanctions

The CSSF fined nine AIFMs EUR 10,000 each for failing to file the 2024 AML/CFT questionnaire (decisions of 11 September 2025, published 9 January 2026). On 17 January 2024, it fined one AIFM EUR 10,000 for not filing the 21/788 external report for year-end 31 December 2022, and reprimanded three other AIFMs. Published decisions are tracked in CSSF and AED AML/CFT sanctions for funds and in our news.

What changed in 2026

Four changes from 2026 matter before you prepare 2027:

  • AMLA templates for the 2026 data collection. For its 2026 campaign, the CSSF replaced its annual Questionnaire on Financial Crime with AMLA data-collection templates (circular letter of 12 February 2026). Deadlines were 22 April 2026 for entities in AMLA's calibration sample and 22 May 2026 for all others (circular letter of 16 March 2026). The 2027 modalities are not yet published.
  • A separate AMLA eligibility collection. Under CSSF Circular 26/914 of 25 June 2026, its addressees had to submit via eDesk AMLA's template for the identification of entities eligible for direct supervision, by 22 July 2026. This exercise is distinct from the annual data collection, and AMLA's selection takes place in 2027.
  • AED reporting for other AIFs on invitation. The questionnaire and the RC report of other AIFs (data at 31 December 2025) were filed only on AED invitation.
  • The 21/788 report, a topic for discussion. In our practice, the 21/788 external report was filed in 2026 (financial years 2025) for the registered AIFMs we follow. Because the CSSF replaced its Financial Crime Questionnaire with the AMLA templates that year, the section corroborating the questionnaire answers was not performed. Whether auditors will be asked to corroborate the AMLA template answers in future years is an open question: nothing had been published at 4 October 2026. We suggest raising the point with your réviseur d'entreprises agréé when you plan the next report.

Preparing the 2027 reporting season

We recommend building the annual reports from data collected during the year, not at reporting time.

  • Map your entities. List each fund and manager with its supervisor and its year-end, then read across the matrix above.
  • Fix the board date. Plan the meeting where the RC presents the year's findings before the SRRC is filed.
  • Collect investor and asset data early. The transfer agent's year-end extract, the asset due diligence files and the delegates' questionnaires feed every report.
  • Agree the timetable with the auditor. Discuss the external report with your réviseur d'entreprises agréé as soon as the audit is planned.
  • Keep a single findings register. In the SRRC, prior-period findings keep their tracking code, so a running register saves rework.

Your annual monitoring plan is where most of this evidence is produced during the year. The RC Annual Reporting Playbook 2027 turns these steps into a back-plan and a data checklist for the SRRC and the AED RC report.

How RC Insight helps

RC Insight is a platform for the RC of Luxembourg funds, built around the reporting cycle. You plan the year's AML/CFT controls for each fund, record each test with its evidence and follow findings to closure. You prepare the AED questionnaire and RC report and the CSSF report section by section in the platform, and track progress to submission. Alerts tell you when a reporting deadline approaches, and the audit trail logs every action with its author and date. To prepare the coming season, download the free RC Annual Reporting Playbook 2027. The product itself is presented on RC software for Luxembourg funds and SRRC and AED report features.

FAQ

What AML/CFT reports does a Luxembourg fund file each year?

It depends on the supervisor and on the management set-up. A CSSF-supervised fund with a Luxembourg IFM files neither the SRRC nor the 21/788 report, but its RC prepares the Article 42(6) summary report for the board. A self-managed CSSF-supervised fund files the SRRC and the 21/788 report. A RAIF files the AED questionnaire and RC report.

When is the SRRC due in 2027?

The SRRC is due within five months after the closing of the annual accounts, exclusively via eDesk. For a 31 December 2026 year-end, that is 31 May 2027; for a 30 June 2027 year-end, it is 30 November 2027. There is no fixed calendar date that applies to every entity.

When are the AED questionnaire and RC report due in 2027?

For RAIFs, the deadline for reference year 2026 is expected to be 31 May 2027, a date the AED confirms each year. Both documents go to aed.raif@en.etat.lu: the questionnaire in Excel with data as at 31 December, the RC report as a signed PDF. In 2026, other AIFs filed only on AED invitation.

Is the SRRC the same as the CSSF AML/CFT data collection?

No: the SRRC (AML/CFT Summary Report RC) is a summary report under Circular 24/854, prepared by the RC and submitted by the RR. The data collection is a separate exercise: in 2026, the CSSF replaced its Questionnaire on Financial Crime with AMLA data-collection templates, filed on eDesk by the RC or the RR.

Does a fund with a foreign IFM file the SRRC?

Yes: a CSSF-supervised fund with a foreign IFM files its own SRRC, not its foreign IFM, and has no 21/788 external report to file. In our practice, such a fund did not file the AMLA data-collection templates in 2026. Its RC also prepares the Article 42(6) summary report for the board.

Who submits the reports, the RC or the RR?

The RC prepares the SRRC and the RR submits it, remaining accountable even if the technical submission is delegated. The 21/788 report may be submitted by the RC, the RR or a board member, under the board's responsibility. In our practice, every communication with the supervisors stays under the RR's responsibility; the RR may mandate the RC to send it.

Is the 21/788 external report still filed after the 2026 changes?

In our practice, the 21/788 external report was filed in 2026 for the registered AIFMs we follow, without the section corroborating the questionnaire answers. Whether auditors will be asked to corroborate the AMLA template answers in future years is an open question: nothing had been published at 4 October 2026.

Sources

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