Supervision

CSSF or AED? Which authority supervises your Luxembourg fund for AML/CFT (with the 2026–2027 reporting calendar)

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: 13 min read

The AML/CFT supervisor follows the entity, not the group. The CSSF supervises all Luxembourg investment fund managers and CSSF-regulated funds (UCITS, Part II UCIs, SIFs, SICARs, ELTIFs). The AED supervises RAIFs and other Luxembourg AIFs not prudentially supervised by the CSSF, such as unregulated SCSps. A RAIF stays with the AED even when its AIFM is CSSF-authorised.

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CSSF or AED? Find your AML/CFT supervisor

Answer up to three questions to see who supervises the entity for AML/CFT, how the RR and RC are notified, and what the RC files each year.

Indicative — confirm with your legal adviser/supervisor. Content reviewed 26 September 2026.

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Key takeaways

  • The CSSF supervises all Luxembourg IFMs (including registered AIFMs) and CSSF-regulated funds: UCITS, Part II UCIs, SIFs, SICARs and ELTIFs.
  • The AED supervises RAIFs and other Luxembourg AIFs not prudentially supervised by the CSSF, such as unregulated SCSp/SCS/SCA AIFs.
  • A RAIF is supervised by the AED even when its AIFM is CSSF-authorised: two entities, two supervisors, two sets of obligations.
  • CSSF entities file the SRRC within five months of year-end via eDesk; AED RAIFs file the questionnaire and RC report by 31 May.
  • The AMLR applies from 10 July 2027 and AMLA direct supervision starts on 1 January 2028.
On this page
  1. Why the CSSF vs AED question matters for your RC
  2. Master mapping table: who supervises what, and what you file
  3. RAIFs: why a RAIF with an authorised AIFM still reports to the AED
  4. Unregulated SCSp, SCS and SCA: the authorised-AIFM case
  5. De minimis (registered) AIFMs: who supervises whom
  6. Edge cases: foreign IFM, ELTIF and change of regime
  7. What each supervisor expects from the RC
  8. AML/CFT reporting calendar 2026–2027 for Luxembourg funds
  9. How RC Insight helps
  10. FAQ
  11. Sources

Why the CSSF vs AED question matters for your RC

Every Luxembourg investment fund and every investment fund manager subject to AML/CFT supervision must appoint both an RR and an RC. The fund's obligations are its own: the AED states that the AIFM's compliance "never exempts" a RAIF from its own AML/CFT obligations.

Getting the supervisor wrong means notifying the wrong authority, preparing the wrong deliverable and missing the right deadline. A single RC can report to both authorities in the same month for entities of the same fund range.

The split exists because the amended Law of 12 November 2004 allocates AML/CFT supervision by type of professional. The CSSF supervises for AML/CFT all Luxembourg IFMs (UCITS management companies, authorised AIFMs and registered AIFMs) and CSSF-regulated funds: UCITS, Part II UCIs, SIFs, SICARs and ELTIFs. The AED (Administration de l'enregistrement, des domaines et de la TVA) supervises for AML/CFT RAIFs and other Luxembourg AIFs not prudentially supervised by the CSSF (e.g. unregulated SCSp/SCS/SCA AIFs), under Articles 2-1(8), 1(3a)(e) and 2(1) point 7 of the AML Law.

Master mapping table: who supervises what, and what you file

This table maps each vehicle and manager type to its AML/CFT supervisor, RR/RC notification channel and annual deliverables.

Vehicle / regime × manager AML/CFT supervisor RR/RC notification channel Annual RC deliverable Annual questionnaire / data collection
Luxembourg IFMs (UCITS ManCo, authorised AIFM, registered AIFM) CSSF AML/CFT Market Entry Form on eDesk; changes communicated in advance SRRC (Circular 24/854) within 5 months of year-end, via eDesk; 21/788 external report within 6 months CSSF financial-crime data collection (AMLA templates on eDesk in 2026)
UCITS, Part II UCI, SIF, SICAR managed by a Luxembourg IFM CSSF Market Entry Form on eDesk Covered by the Luxembourg IFM's SRRC; the fund's RC still prepares the annual Art. 42(6) summary report, which the CSSF may request (SRRC FAQ 2A); exempt from 21/788 (fund has designated an IFM) Completed by the IFM
UCITS, Part II UCI, SIF, SICAR self-managed or with a foreign IFM CSSF Market Entry Form on eDesk Own SRRC within 5 months of year-end; 21/788 external report within 6 months for self-managed funds only: a fund with a foreign IFM is exempt CSSF data collection, filed by the fund itself (a foreign IFM does not file it)
ELTIF CSSF Market Entry Form on eDesk Listed in the SRRC scope among funds with no Luxembourg IFM filing on their behalf CSSF data collection
RAIF (any AIFM, including a CSSF-authorised one) AED (the AIFM stays with the CSSF) AED RR/RC identification form, in its original format and unsigned, to AED.finvehicles@en.etat.lu, at first appointment and after any change AED annual RC report (signed PDF) by 31 May AED AML/CFT questionnaire (Excel, data at 31 December) by 31 May
Unregulated SCSp / SCS / SCA AIF with an authorised Luxembourg AIFM AED for the AIF; CSSF for the AIFM (see next section) AED RR/RC identification form to AED.finvehicles@en.etat.lu AED RC report on AED invitation AED questionnaire on AED invitation, via aed.aif@en.etat.lu
Unregulated AIF with a registered (de minimis) AIFM AED for the AIF; CSSF for the registered AIFM AED RR/RC identification form to AED.finvehicles@en.etat.lu; where the general partner is itself the registered AIFM, an RC at both levels (see the de minimis section) AED RC report on AED invitation AED questionnaire on AED invitation

Two rules sit behind every row. First, the fund and its manager are two professionals, each with its own RR, RC and filings. Second, the SRRC is a summary report, not a questionnaire: the CSSF questionnaire is a separate data collection.

RAIFs: why a RAIF with an authorised AIFM still reports to the AED

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. Two entities, two supervisors, two sets of obligations.

The AED describes RAIFs as financial vehicles "not prudentially supervised by the CSSF or any other Luxembourg supervisory authority". The AIFM's authorisation does not change the RAIF's status, which is why "RAIFs are unregulated, so AML is lighter" is the wrong framing: RAIFs carry full AML/CFT obligations under AED supervision.

Worked example: RAIF SCSp + GP + authorised AIFM + TA

Take a common private-equity set-up: Alpha Growth RAIF SCSp, its general partner Alpha GP S.à r.l., an external authorised Luxembourg AIFM, and a Luxembourg transfer agent performing investor KYC under delegation.

Entity AML/CFT role Supervisor for this structure What it files, and where
Alpha Growth RAIF SCSp Professional in its own right AED RR/RC identification form (AED.finvehicles@en.etat.lu); annual questionnaire (Excel) and RC report (signed PDF) by 31 May
Alpha GP S.à r.l. Its board of managers can act as the RAIF's RR Through the RAIF Board resolutions appointing the RR and RC, sent to the AED with the identification form
Authorised AIFM Separate professional CSSF Its own Market Entry Form entries, SRRC within 5 months of its year-end, 21/788 external report, CSSF data collection
Transfer agent Delegated investor due diligence Its own supervisor, per its licence Nothing for the RAIF; the RAIF's RC reports on controls over this delegation

The RR of a fund may be the board of directors (or board of managers of the general partner) acting as a collegial body, or one designated board member. For an SCSp such as Alpha Growth, the RR therefore sits at general partner level: the board of managers of Alpha GP S.à r.l. acting collegially, or one of its managers. On the AED form, the AED suggests sending the form without signatures and providing the signed board minutes or circular resolutions separately.

Who submits what also differs inside the RAIF. The AED questionnaire is transmitted by the RR, who may delegate the task to the RC. The RC report is sent by the RC. The RC report must cover at least a dozen topics, including the risk assessment, due diligence on investors, initiators and portfolio managers, PEPs, asset due diligence, suspicious transaction reports to the CRF, sanctions/freezing reports and breaches identified. Controls over delegated tasks, such as the TA's investor KYC, are one of those topics. Our AED RC report for RAIFs walks through each item.

Unregulated SCSp, SCS and SCA: the authorised-AIFM case

The AED's page on other AIFs places in its AML/CFT scope Luxembourg AIFs that are "financial vehicles not prudentially supervised by the CSSF or any other Luxembourg supervisory authority". An unregulated SCSp managed by an authorised AIFM is not itself prudentially supervised by the CSSF: only its AIFM is. On that basis, the AIF falls under AED AML/CFT supervision, and the AED invites all AIFs to file the RR/RC identification form.

The CSSF, for its part, looks at the same fund through its manager. In a July 2021 publication on AML/CFT controls applied to unregulated AIFs, it described "the indirect supervision of the unregulated AIFs through the supervision of its IFM". The CSSF expects the IFM to analyse the ML/TF risk of the AIF's investments, monitor delegated AML/CFT tasks and screen investment relationships against sanctions lists.

In practice, treat it as a dual layer:

  • The unregulated AIF appoints its own RR and RC, notifies them to the AED (AED.finvehicles@en.etat.lu) and answers the AED questionnaire and RC report when invited.
  • The authorised AIFM covers the AML/CFT controls it applies to the AIFs it manages in its own CSSF framework (SRRC, 21/788, data collection).

The AED's published pages do not distinguish between AIFs managed by authorised and registered AIFMs. If your structure has unusual features (a foreign AIFM, an AIF in liquidation, a vehicle whose AIF status is itself debated), confirm the position with the AED and your legal adviser before the next campaign.

De minimis (registered) AIFMs: who supervises whom

Registered AIFMs (the "de minimis" managers below the AIFMD thresholds) are Luxembourg IFMs. The CSSF supervises them for AML/CFT like any other IFM. They are in the SRRC scope, and CSSF Circular 21/788 expressly covers "all Luxembourg investment fund managers including registered AIFMs".

The unregulated AIFs they manage, typically SCSps, are AED-supervised AIFs. So a de minimis structure also has two supervisors: the CSSF for the registered AIFM, the AED for the fund. A common case is an SCSp whose general partner is itself the registered AIFM. The SCSp's RR sits at general partner level (its board of managers acting collegially, or one of its managers), and an RC must be appointed at both levels: at the general partner, in its capacity as registered AIFM, and at the SCSp. The CSSF's enforcement record shows why the manager side matters: it 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).

Edge cases: foreign IFM, ELTIF and change of regime

CSSF-supervised fund with a foreign IFM. The SRRC scope includes CSSF-supervised investment funds with no Luxembourg IFM filing on their behalf (e.g. self-managed funds, funds with a foreign IFM, ELTIFs). A Luxembourg SIF managed by a French or Irish manager therefore files its own SRRC, unless one of the exceptions in the SRRC FAQ applies (1C: a Luxembourg IFM providing UCIA services is also appointed; 1E: a Luxembourg IFM is appointed before the submission date; 1F: the fund has left the CSSF official list by the expected submission date). The same fund, not its foreign IFM, also files the CSSF annual financial-crime data collection (the AMLA templates, formerly the financial crime questionnaire). It has no 21/788 external report to file: Circular 21/788 exempts funds that have appointed an IFM "established in Luxembourg or abroad" (section 1.2). That report concerns Luxembourg IFMs and self-managed funds.

ELTIF. ELTIFs sit on the CSSF side and are in the SRRC scope (FAQ 1D answers "Yes"). The FAQ does not address an ELTIF whose Luxembourg IFM already files an SRRC: in that case, confirm with the CSSF whether the ELTIF files its own.

Change of regime (for example a SIF converting into a RAIF). The supervisor follows the regime. Once the vehicle is a RAIF, it leaves CSSF prudential supervision and enters the AED scope, so the AED RR/RC identification form must go out "without delay" as a first appointment. Agree the handover with both authorities, including which supervisor receives the report for the transition year. No published guidance fixes that point, so document your approach.

What each supervisor expects from the RC

CSSF: eDesk, SRRC, 21/788 and the annual data collection

  • Market Entry Form. CSSF-supervised funds and IFMs notify their RR and RC through the AML/CFT Market Entry Form on eDesk at set-up. Changes must be communicated to the CSSF in advance.
  • SRRC. The SRRC (AML/CFT Summary Report RC) is governed by CSSF Circular 24/854 of 29 February 2024. It replaced the former annual RC report for the collective investment sector and applies to financial years ending on or after 31 December 2023. SRRC deadline: within five months after the closing of the annual accounts, submitted exclusively via eDesk. It is not a fixed calendar date (31 May only for a 31 December year-end). The RC prepares the SRRC. The RR submits it and remains accountable, even if the technical submission is delegated. Our SRRC guide covers the template section by section.
  • 21/788 external report. CSSF Circular 21/788 (17 December 2021): annual AML/CFT external report by the réviseur d'entreprises agréé, due within six months after year-end via eDesk. Funds that have designated an IFM, established in Luxembourg or abroad, are exempt from filing it (section 1.2).
  • Data collection. CSSF annual financial-crime data collection: for reference year 2025, Luxembourg IFMs and funds without a Luxembourg IFM (self-managed or with a foreign IFM) completed the AMLA data-collection templates on eDesk (launched 2 March 2026). Deadlines were 22 April 2026 (entities in AMLA's calibration sample) and 22 May 2026 (all others). Dates change every year: always check the CSSF circular letter.

AED: identification form, questionnaire and RC report

  • RR/RC identification form. AED-supervised RAIFs and other AIFs notify their RR and RC with the AED RR/RC identification form, at first appointment and after any change. The AED asks for it to be sent without delay to AED.finvehicles@en.etat.lu, unsigned, as the completed fillable PDF form in its original format (2 MB maximum): a scan of the printed form is not accepted.
  • RAIFs. AED, RAIFs: the annual AML/CFT questionnaire (Excel, data as at 31 December) and the annual RC report (signed PDF) are due by 31 May (close of business), sent to aed.raif@en.etat.lu. For reference year 2025 the deadline was 31 May 2026. The AED rejects scanned PDFs and non-original formats.
  • Other AIFs. AED, other unregulated AIFs: reporting was extended to non-RAIF AIFs in February 2025 (deadline 30 June 2025 for 2024). For reference year 2025 the questionnaire is filed on AED invitation, via aed.aif@en.etat.lu. The absence of an invitation does not exempt a fund from its legal obligations. The AED applies the same invitation-only rule to the RC report of non-RAIF AIFs for 2025.

AML/CFT reporting calendar 2026–2027 for Luxembourg funds

The calendar assumes a 31 December financial year-end. For another year-end, move the SRRC and 21/788 rows accordingly (five and six months after closing). Confirmed means a legal rule or a published date. Expected means a recurring date that the authority has not yet announced for 2027.

Month Obligation Who Supervisor Channel Status / source
Any time (event-driven) RR or RC appointment or change Funds and IFMs CSSF Market Entry Form on eDesk, before the change Confirmed (CSSF MEF FAQ)
Any time (event-driven) RR or RC appointment or change RAIFs; other AIFs AED Identification form to AED.finvehicles@en.etat.lu, without delay Confirmed (pfi.public.lu)
November 2026 SRRC for 30 June 2026 year-ends IFMs; funds without a Luxembourg IFM CSSF eDesk Confirmed rule (5 months, Circular 24/854)
December 2026 21/788 external report for 30 June 2026 year-ends IFMs; funds without an IFM CSSF eDesk Confirmed rule (6 months, Circular 21/788)
February–March 2027 Launch of the annual financial-crime data collection (reference year 2026) Luxembourg IFMs; funds without a Luxembourg IFM CSSF eDesk Expected. 2026 example: launched 2 March 2026
April–May 2027 Data-collection deadlines Luxembourg IFMs; funds without a Luxembourg IFM CSSF eDesk Expected. 2026 example: 22 April and 22 May 2026
31 May 2027 SRRC for 31 December 2026 year-ends IFMs; funds without a Luxembourg IFM CSSF eDesk Confirmed rule (5 months)
31 May 2027 AML/CFT questionnaire + annual RC report (reference year 2026) RAIFs AED aed.raif@en.etat.lu Expected: 31 May is the recurring AED date; 2027 campaign not yet published
2027, on invitation Questionnaire + RC report (reference year 2026) Non-RAIF AIFs invited by the AED AED aed.aif@en.etat.lu Expected (2026 cycle was invitation-only)
30 June 2027 21/788 external report for 31 December 2026 year-ends IFMs; funds without an IFM CSSF eDesk Confirmed rule (6 months)
10 July 2027 AMLR (Regulation (EU) 2024/1624) applies; 6th AML Directive transposition deadline All obliged entities CSSF / AED n/a Confirmed (EUR-Lex)
H2 2027 AMLA selects up to 40 entities for direct supervision Selected obliged entities AMLA n/a Confirmed timeline
1 January 2028 AMLA direct supervision starts Selected entities AMLA n/a Confirmed timeline

The EU AML Regulation (AMLR), Regulation (EU) 2024/1624, applies from 10 July 2027. AMLR treats AIFs and their AIFMs, and UCITS and their management companies, as obliged entities. Map your RR/RC set-up against the AMLR before that date.

How RC Insight helps

RC Insight is the compliance operating system for Responsables du Contrôle. For each mandate, it records the supervisor (CSSF or AED), the year-end and the manager, then generates the deadlines that apply: SRRC and 21/788 dates computed from each year-end, the AED 31 May campaign, invitation-based filings and RR/RC change notifications. Multi-mandate RCs see every CSSF and AED deadline in one view, with reminders and an evidence trail for each submission. The AED RC report and the SRRC draw on the same monitoring data, so you document a control once and reuse it for both supervisors.

Request a 30-minute demo and load your own mandates.

FAQ

Who supervises AML/CFT for Luxembourg RAIFs?

The AED (Administration de l'enregistrement, des domaines et de la TVA) supervises RAIFs for AML/CFT. RAIFs are not prudentially supervised by the CSSF, so they fall within the AED's scope under the amended Law of 12 November 2004. The RAIF notifies its RR and RC to the AED and files the AED questionnaire and RC report.

Is a RAIF supervised by the CSSF if its AIFM is authorised?

No. 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: two entities, two supervisors, two sets of obligations. The AIFM's compliance never exempts the RAIF from its own AML/CFT obligations.

Who supervises an unregulated SCSp for AML/CFT?

The AED supervises unregulated Luxembourg AIFs, such as SCSp, SCS or SCA AIFs, because they are not prudentially supervised by the CSSF. Their Luxembourg AIFM, authorised or registered, remains supervised by the CSSF, which also oversees the AML/CFT controls the AIFM applies to the AIFs it manages. Confirm unusual structures with your adviser.

What is the AED RC report deadline?

For RAIFs, the annual RC report (signed PDF) and the AML/CFT questionnaire (Excel, data at 31 December) are due by 31 May, close of business, to aed.raif@en.etat.lu. For reference year 2025 the deadline was 31 May 2026. Non-RAIF AIFs file on AED invitation, via aed.aif@en.etat.lu.

Does the AED require a questionnaire for non-RAIF AIFs?

Yes, on invitation. AED reporting was extended to non-RAIF AIFs in February 2025, with a 30 June 2025 deadline for 2024. For reference year 2025, the questionnaire is filed on AED invitation via aed.aif@en.etat.lu. The absence of an invitation does not exempt a fund from its legal AML/CFT obligations.

What is the difference between the CSSF and the AED for AML/CFT?

The CSSF supervises Luxembourg IFMs and CSSF-regulated funds (UCITS, Part II UCIs, SIFs, SICARs, ELTIFs) and works through eDesk: Market Entry Form, SRRC and annual data collection. The AED supervises RAIFs and other unregulated AIFs and works by email: RR/RC identification form, Excel questionnaire and signed RC report.

Which authority receives the RC's identity?

It depends on the entity. CSSF-supervised funds and IFMs notify their RR and RC through the AML/CFT Market Entry Form on eDesk, and changes are communicated in advance. AED-supervised RAIFs and other AIFs send the AED RR/RC identification form in its original format, at first appointment and after any change.

Sources

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