RC Annual Reporting
Playbook 2027
File the CSSF SRRC and the AED RC report on time, with evidence. The method our team runs on its own mandates, season after season.
- A 120-day plan, T-120 to T0, with the 2027 dates for four financial year-ends
- A 54-point data checklist: source to chase, evidence to keep, one owner each
- A 21-box quality review checklist to run before you file
- Three ready-to-send templates: two request e-mails and a board memo
- 32
- pages, A4
- 120
- days, kick-off to filing
- 54
- data points, one owner each
- 21
- checks before you file
- 3
- ready-to-send templates
Pick your financial year-end.
See your four key dates.
The CSSF deadlines follow your year-end. Kick-off and board dates are the milestones we recommend; the playbook back-plans twelve workstreams around them.
T-120 · Kick-off
31 Jan 2027
A Sunday: kick off on Monday 1 February 2027.
T-21 · Board
10 May 2027
Freeze the figures; the board acknowledges the findings.
T0 · SRRC deadline
31 May 2027
Within five months of the year-end, through eDesk.
21/788 external report
30 Jun 2027
Year-end + 6 months, filed through eDesk.
Running a RAIF? Its AED questionnaire and RC report follow a different clock: 31 May 2027, whatever the year-end, with data as at 31 December 2026. The AED confirms the date each year on pfi.public.lu. Other unregulated AIFs file on AED invitation.
Get the full 120-day plan →Working pages, not a white paper.
Tables you fill in, checklists you tick, e-mails you send. One idea per page, in season order.
Four parts, in season order.
Written for independent and outsourced RCs, compliance teams at ManCos and AIFMs, RRs and board members, and the administrators and transfer agents who supply the data.
- 01p. 6
Scope
Which report you owe, to whom, through which channel: six deliverables and a who-files-what matrix.
- 02p. 9
Timing
The two clocks, the deadlines for four year-ends and twelve workstreams back-planned from T0.
- 03p. 14
Data
Eleven data areas that feed both reports, and the map of the 15 SRRC sections and 12 AED topics.
- 04p. 17
Sign-off
Twelve weaknesses reviewers find, with the fix; the quality review checklist; three templates.
- Ap. 26
Appendix: master data checklist
54 data points with the source to chase, the evidence to keep, an owner and a due date.
Written by the RC Insight team, practitioners who have supported more than 80 fund promoters in setting up their AML/CFT framework since 2020.
Built on primary sources
CSSF Circular 24/854 and the CSSF SRRC FAQ and user guide · CSSF Regulation 12-02 · CSSF Circular 21/788 · AED guidance for RAIFs.
General information, not legal advice. Last reviewed 30 September 2026; regulatory dates are reviewed every January and September.
Questions RCs ask us
When is the SRRC due?
Within five months of the end of the financial year, through the CSSF eDesk portal. For a 31 December 2026 year-end, that is 31 May 2027. The playbook gives the dates for 31 March, 30 June and 30 September year-ends too.
When do RAIFs file with the AED?
The AED questionnaire and RC report of a RAIF are expected by 31 May, by e-mail, with data as at 31 December. The AED confirms the date each year on pfi.public.lu. Other unregulated AIFs file on AED invitation, and no invitation does not mean no obligation.
Is an annual RC report due even without an SRRC?
Yes. A fund with a Luxembourg IFM files no SRRC, but its RC still prepares, at least once a year, the summary report of Article 42(6) of CSSF Regulation 12-02 for the RR, the authorised management and the board. It is not sent to the CSSF automatically, but the CSSF may ask for it (SRRC FAQ 2A).
What does the playbook cost, and what happens to my e-mail?
It is free. We send it to your inbox, follow up with two short e-mails on how to use it, and you can unsubscribe in one click. The regulatory updates are only sent if you tick the box.
Can I share it with my team or my delegates?
Yes. You may share the playbook in full with attribution to www.rcinsight.lu. The templates are illustrative: adapt them to your structure and policies.
Start the season at T-120, not in May.
For a 31 December year-end, kick off on Monday 1 February 2027.