LUXEMBOURG Trends and Developments Contributed by: Claudia Hoffmann, Daniel Krauspenhaar, Stefanie Samosny and Sascha Wiemann, Luther
agility and its commitment to maintaining an attractive and competitive framework for investors, as well as for regulated AIFs. On 6 March 2025, the Commission de Surveillance du Secteur Financier (CSSF) published a communication regarding the implementation of a new “e-Identifica - tion” system, replacing the existing VISA procedure for prospectuses of UCITS, Part II UCIs, SICARs and SIFs. Fund prospectuses will now visibly showcase a unique identification number and an e-Identification date on their first page. The transition will occur through the dedicated eDesk e-Identification Prospectus application and will apply to submissions of any new or revised fund prospectus. Additionally, the CSSF will change its administrative procedures through the establishment of a new cata - logue of prospectus amendments that do not legally require authorisation and prior review by the CSSF. An additional guide was subsequently also published by the CSSF, including details on the new proce - dure, a list of amendments to the prospectus (which do not legally require authorisation and prior review by the CSSF), the applicable conditions, a technical part to facilitate IT and operational implementation, and an FAQ section. The new guidelines modernise administrative procedures for the benefit of market participants, while at the same time emphasise the responsibility of each fund’s governing body to ensure regulatory compliance. Omnibus Simplification Package On 26 February 2025, the European Commission presented the “Omnibus I” Simplification Package to ease sustainability reporting and due diligence rules under: • the Corporate Sustainability Reporting Directive – formally Directive (EU) 2022/2464 of the European Parliament and of the Council on sustainability reporting by companies (CSRD); • the Corporate Sustainability Due Diligence Direc - tive – formally Directive (EU) 2024/1760 of the European Parliament and of the Council on corpo - rate sustainability due diligence (CSDDD); and • Regulation (EU) 2020/852 of the European Parlia - ment and of the Council on the establishment of a
framework to facilitate sustainable investment (the “Taxonomy Regulation”). Under the CSDDD, compliance for the largest compa - nies is delayed by one year, to mid-2028. The Council of the EU confirmed the 1,000-employee threshold under the CSRD but added a EUR450 million turn - over requirement and introduced a review clause. For the CSDDD, it raised thresholds significantly to 5,000 employees and EUR1.5 billion turnover, limit - ing obligations to very large companies. In parallel, the European Parliament’s rapporteur has proposed even higher, uniform thresholds across all three laws, the removal of mandatory climate transition plans, and greater harmonisation of sustainability standards to reduce compliance complexity. The Parliament is expected to adopt its position in autumn 2025, fol - lowed by trilogue negotiations with the Council and Commission. While focused on the CSRD and CSDDD, the Omni - bus is widely regarded as a stepping stone towards the anticipated revision of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR). In May 2025, the European Commission launched a “Call for evi - dence for an impact assessment”, which forms part of a comprehensive review of the SFDR and has included public and targeted consultations, technical workshops, and engagement with member states. The forthcoming proposal (expected for Q4 2025, but which might only be finalised following the publica - tion of the Omnibus package to ensure consistency with the CSRD and CSDDD) is expected to streamline sustainability classifications and disclosure require - ments, thereby reducing complexity, enhancing com - parability and providing fund managers with a more coherent framework for integrating sustainability into their strategies. Secondaries The interest in the fund secondaries market has con - tinued to increase in recent years, for a number of reasons. The Luxembourg funds market is well estab - lished in this respect, with one trend being the use of continuation funds. Through the introduction of EM3S, the Luxembourg Stock Exchange (LuxSE) has now
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