Starting April 2025, the CSSF has introduced a new e-Identification system to replace the current VISA procedure for fund prospectuses, including UCITS, Part II UCIs, SICARs, and SIFs.
The key changes include:
- each prospectus will receive a unique identification number and an e-Identification date, both displayed on the first page.
- submissions for new or revised prospectuses will go through the eDesk e-Identification Prospectus application.
- certain amendments will no longer require prior CSSF approval, as outlined in a dedicated guide available via eDesk (the “Guide”), including among others (i) additional share class(es) set up but not registered with the CSSF excluding class(es) with restrictions in distribution or ETF share classes, (ii) amendments to the initiator in the prospectus (iii) increases, decreases of fees or changes to the fee structure, and (iv) not-material changes to an existing fund or sub-fund.
In other words, this means that the administrative process will be streamlined, reducing approval delays for non-critical changes. The CSSF may still however conduct ex-post reviews of changes that were not pre-approved. Additionally, the governing body of each fund will bear greater responsibility for compliance.
To increase operational efficiency, the process supports automation via API (S3).
The Guide which was released on 20 March 2025 also includes a technical part facilitating IT and operational implementation. This modernisation aims to improve efficiency while upholding strong investor protection standards.
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