The CSSF annual AML/CFT data collection (AMLA templates)
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: 9 min read
The CSSF annual AML/CFT data collection is the yearly AML/CFT data that investment fund managers, including registered AIFMs, and investment funds which did not designate an IFM file on eDesk. For the 2026 campaign (reference year 2025), the CSSF replaced its annual Questionnaire on Financial Crime with AMLA data-collection templates, filed by the RC or the RR.
You may also know it as the CSSF AML questionnaire for investment fund managers. It is not the SRRC, the RC's summary report under CSSF Circular 24/854. This page covers who files, what changed with the AMLA templates and how to prepare the next campaign; for every annual deliverable of a Luxembourg fund, see our guide to annual AML/CFT reporting for Luxembourg funds.
Key takeaways
- 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.
- Addressees: investment fund managers including registered AIFMs, Luxembourg branches of investment fund managers, SIAG, FIAAG and investment funds which did not designate an investment fund manager.
- The 2026 deadlines were 22 April 2026 for entities in AMLA's calibration sample and 22 May 2026 for all other addressees; the 2027 dates have not been published yet.
- It is not the SRRC, and it is distinct from the AMLA eligibility template of CSSF Circular 26/914.
- In our practice, a fund with a foreign IFM did not file the AMLA data-collection templates in 2026.
On this page
- What the CSSF annual AML/CFT data collection is, and what it is not
- Who files the CSSF annual AML/CFT data collection
- The 2026 campaign: AMLA templates replaced the Financial Crime Questionnaire
- The link with the 21/788 external report
- Not to be confused with the AMLA eligibility template
- Preparing for the 2027 campaign
- How RC Insight helps
- FAQ
- Sources
What the CSSF annual AML/CFT data collection is, and what it is not
The data collection is a yearly set of AML/CFT data that the CSSF collects on eDesk from investment fund managers and from investment funds which did not designate an IFM. The CSSF used to collect this data through its annual Questionnaire on Financial Crime; for the 2026 campaign, it replaced that questionnaire with AMLA data-collection templates (circular letter of 12 February 2026).
Other exercises are often confused with it. The table sets them side by side.
| Exercise | What it is | Who files | When |
|---|---|---|---|
| CSSF annual data collection (AMLA templates) | The CSSF's annual AML/CFT data collection; in 2026, AMLA data-collection templates replaced the Questionnaire on Financial Crime. | Each addressee, on eDesk, through its RC or its RR. | 2026 campaign: 22 April 2026 (AMLA calibration sample) or 22 May 2026 (all other addressees). |
| SRRC (AML/CFT Summary Report RC) | The RC's summary report, governed by CSSF Circular 24/854. | Prepared by the RC; submitted by the RR, who remains accountable. | Within five months after the closing of the annual accounts, exclusively via eDesk. |
| External report under Circular 21/788 | Annual AML/CFT external report by the réviseur d'entreprises agréé. | Submitted via eDesk by the RC, the RR or a board member, under the board's responsibility. | Within six months after year-end. |
| AMLA eligibility template (Circular 26/914) | AMLA's template for the identification of entities eligible for direct supervision. | The addressees of Circular 26/914, via eDesk. | Campaign opened 20 July 2026; deadline 22 July 2026. |
The SRRC is a summary report, not a questionnaire, and it has its own scope and deadline rules: see our guide to the SRRC and Circular 24/854. The data collection and the SRRC both draw on the AML/CFT data of the year. We recommend reconciling them before filing, so that investor counts and risk levels tell the same story.
Who files the CSSF annual AML/CFT data collection
The 2026 circular letters name the addressees word for word: "Investment fund managers including registered AIFMs, Luxembourg branches of investment fund managers, SIAG, FIAAG and investment funds which did not designate an investment fund manager". The templates are filed on eDesk by the RC or the RR. In our practice, every communication with the supervisors stays under the RR's responsibility; the RR may mandate the RC to send it.
| Your entity | Position for the 2026 campaign |
|---|---|
| Luxembourg investment fund manager (for example, a UCITS management company or an authorised AIFM) | Addressee: "investment fund managers". |
| Registered AIFM | Addressee: "including registered AIFMs". |
| Luxembourg branch of an investment fund manager | Addressee: "Luxembourg branches of investment fund managers". |
| Fund that did not designate an IFM | Addressee: "investment funds which did not designate an investment fund manager"; SIAG and FIAAG are listed separately. |
| Fund with a Luxembourg IFM | Not listed in its own right: the fund designated an IFM, and its IFM is an addressee. |
| CSSF-supervised fund with a foreign IFM | In our practice, such a fund did not file the AMLA data-collection templates in 2026. |
| RAIF supervised by the AED | Supervised by the AED for AML/CFT even when its AIFM is CSSF-authorised; it files the AED annual AML/CFT questionnaire and RC report. |
For the AED side, see our guide to the AED RC report and questionnaire for RAIFs.
Funds with a foreign IFM
A CSSF-supervised fund with a foreign IFM files its own SRRC (its foreign IFM does not) and has no 21/788 external report to file. For the data collection, the 2026 addressee line covers "investment funds which did not designate an investment fund manager". In our practice, such a fund did not file the AMLA data-collection templates in 2026. We recommend re-reading the addressee line of each campaign rather than relying on the previous year's answer.
The 2026 campaign: AMLA templates replaced the Financial Crime Questionnaire
By circular letter of 12 February 2026, the CSSF replaced its annual Questionnaire on Financial Crime with AMLA data-collection templates, for reference year 2025. A circular letter of 16 March 2026 then set the deadlines.
| Step | 2026 campaign (reference year 2025) |
|---|---|
| Templates announced | CSSF circular letter of 12 February 2026. |
| Deadlines set | CSSF circular letter of 16 March 2026. |
| Deadline for entities in AMLA's calibration sample | 22 April 2026. |
| Deadline for all other addressees | 22 May 2026. |
| Channel and filer | eDesk, by the RC or the RR. |
These dates change every year: always check the CSSF's latest circular letter. The "Last reviewed" date at the top of this page shows when we last checked them.
The templates come from AMLA, the EU Anti-Money Laundering Authority (Regulation (EU) 2024/1620), based in Frankfurt. AMLA will select up to 40 entities for direct supervision in the second half of 2027, and direct supervision starts on 1 January 2028. In our view, the switch to AMLA templates is a reason to treat the data collection as a fixed item of the RC's calendar, not an ad hoc survey.
Failing to file has consequences. 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). We recommend giving the AMLA templates the same discipline as the questionnaire they replaced. For the published decisions, see our overview of AML/CFT sanctions against funds.
The link with the 21/788 external report
Circular 21/788 provides for an external report prepared by the réviseur d'entreprises agréé that audits the entity's annual accounts or, where no audit is legally required, by a réviseur mandated for this purpose. That report has a section corroborating the entity's answers to the CSSF annual AML/CFT online survey. It concerns Luxembourg IFMs and self-managed CSSF-supervised funds; funds that have appointed an IFM, established in Luxembourg or abroad, are exempt.
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.
In our view, the safe course is to raise it with your auditor and keep the evidence behind each answer, so that it can be shown if a corroboration is requested. For who prepares the report and what it contains, see our guide to the CSSF Circular 21/788 external report.
Not to be confused with the AMLA eligibility template
The AMLA eligibility template is a different exercise from the annual data collection. Under CSSF Circular 26/914 (25 June 2026), its addressees had to submit AMLA's template for the identification of entities eligible for direct supervision via eDesk; the campaign opened on 20 July 2026, with a deadline of 22 July 2026. AMLA's selection takes place in 2027.
In short, the annual data collection is the yearly AML/CFT data set for a reference year, while the eligibility template served to identify the entities eligible for AMLA direct supervision. For what AMLA direct supervision means for funds and their managers, see our article on AMLA direct supervision of investment funds.
Preparing for the 2027 campaign
The dates of the 2027 campaign (reference year 2026) have not been published yet, and dates change every year: always check the CSSF's latest circular letter. We do not know yet whether the next campaign will again use the AMLA templates: the steps below are our recommendations and work for either format.
- Decide who files. In 2026, the CSSF let the RC or the RR file the templates. We recommend deciding which of them files and recording that choice. In our practice, every communication with the supervisors stays under the RR's responsibility; the RR may mandate the RC to send it.
- Check eDesk access early. Make sure the RC and the RR can log in to eDesk before the campaign opens, not in the final week.
- Keep the year's data in a single place. Investor population by risk level, PEPs, sanctions screening, suspicious transaction reports and controls performed should not live in scattered spreadsheets.
- Reconcile across filings. Check that the answers match the SRRC of the same year and the entity's risk assessment.
- Keep the evidence. Record the source of each answer, in case the auditor or the CSSF asks for it.
- Re-read the addressee line. A new branch, a fund that changes its IFM or a fund with a foreign IFM should check its position at each campaign.
- Watch the CSSF publications. Put the deadline in the RC calendar as soon as the CSSF announces it.
Our free playbook turns these steps into a preparation plan and a data checklist.
How RC Insight helps
RC Insight is software for the RC of Luxembourg investment funds. Alerts and deadlines notify you when a reporting deadline approaches, and the RC calendar brings the deadlines and open points of each fund into a single view. Investor KPIs show the fund's investor base by country, risk level, PEP status and sanctions screening, from the transfer agent's data received through a secure upload. The monitoring plan records each test with its evidence, and the audit trail logs every action with its author and date, so you can show who did what, and when. The regulatory library lets you follow CSSF publications, filtered by category and date. See how it fits together on our RC software page, or start with the playbook.
FAQ
Is the CSSF data collection the same as the SRRC?
No. The SRRC (AML/CFT Summary Report RC) is the RC's summary report under CSSF Circular 24/854, due within five months after the closing of the annual accounts. The data collection is a separate annual AML/CFT data set, collected in 2026 through AMLA data-collection templates filed on eDesk by the RC or the RR.
Who files the CSSF annual AML/CFT data collection?
The 2026 circular letters name the addressees: investment fund managers including registered AIFMs, Luxembourg branches of investment fund managers, SIAG, FIAAG and investment funds which did not designate an investment fund manager. The templates are filed on eDesk by the RC or the RR.
Does a fund with a foreign IFM file the AMLA templates?
A CSSF-supervised fund with a foreign IFM files its own SRRC 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. We recommend re-reading the addressee line at each campaign, because the scope can change.
What were the 2026 deadlines?
For reference year 2025, the deadlines were 22 April 2026 for entities in AMLA's calibration sample and 22 May 2026 for all other addressees, set by the CSSF circular letter of 16 March 2026. Dates change every year: always check the latest CSSF circular letter before planning.
When is the 2027 campaign?
The dates of the 2027 campaign (reference year 2026) have not been published yet, and dates change every year: always check the CSSF's latest circular letter. We recommend preparing the year's AML/CFT data now and watching CSSF publications from the start of the year, so that the deadline does not arrive as a surprise.
Is the AMLA eligibility template under Circular 26/914 the same exercise?
No. Under CSSF Circular 26/914 (25 June 2026), addressees had to submit AMLA's template for the identification of entities eligible for direct supervision via eDesk, by 22 July 2026. AMLA's selection takes place in 2027. This exercise is distinct from the annual data collection.
Will auditors corroborate the AMLA template answers?
The 21/788 external report has a section corroborating the entity's answers to the CSSF annual AML/CFT online survey. In our practice, that section was not performed in 2026, because the questionnaire had been replaced by the AMLA templates. Whether auditors will corroborate the AMLA template answers in future years remains an open question.
Sources
- CSSF circular letter of 12 February 2026 (AMLA data-collection templates): https://www.cssf.lu/wp-content/uploads/circular_letter_120226_AML_CFT.pdf
- CSSF circular letter of 16 March 2026 (deadlines): https://www.cssf.lu/wp-content/uploads/circular_letter_170326_AML_CFT.pdf
- CSSF Circular 26/914 (AMLA eligibility template): https://www.cssf.lu/wp-content/uploads/cssf26_914eng.pdf
- CSSF Circular 24/854 (SRRC): https://www.cssf.lu/wp-content/uploads/cssf24_854eng.pdf
- CSSF Circular 21/788 (AML/CFT external report): https://www.cssf.lu/wp-content/uploads/cssf21_788eng.pdf
- AED, RAIF AML/CFT questionnaire: https://pfi.public.lu/fr/blanchiment/sf/fiar/aml-cft-questionnaire.html