The Luxembourg financial regulator, the Commission de Surveillance du Secteur Financier (CSSF), has announced a significant shift in the administrative process governing the submission and identification of fund prospectuses. In April 2025, the VISA stamping system has been replaced by a new digital e-Identification procedure. This change applies to prospectuses of UCITS, Part II UCIs, SICARs, and SIFs.
Under the revised framework, each new or amended prospectus submitted to the CSSF receives a unique identification number and an associated e-Identification date. Both elements are clearly displayed on the first page of the prospectus.
Submissions have been transitioned to a newly developed e-Identification module within the CSSF’s eDesk platform. This digital interface is intended to streamline the handling of prospectus filings and support a more efficient, automated process.
Alongside the introduction of this tool, the CSSF implemented a revised administrative approach that distinguishes between changes that require regulatory approval and those that do not. A new list of amendments considered minor—and therefore not subject to prior review—has been established. Such changes may be integrated into the prospectus without the need for prior authorisation from the CSSF. However, the regulator retains the right to request documentation at a later stage as part of its ongoing supervisory responsibilities.
A comprehensive guide has been published via eDesk including the categories of changes exempt from prior review, applicable conditions, procedural instructions, and a FAQ section.
The changes exempting from prior review from the CSSF include inter alia changes in share classes, amendment to the initiator, non-material changes to an existing sub-fund or to the general part of the prospectus, non-material ESMA or other related updates to ensure compliance with FAQs, guidelines and recommendations.
As stated in FAQ document, the amendments can been notified to the CSSF at the same time the updated prospectus is submitted for e-identification on Edesk.
However, should any modification within the prospectus impact the articles of association or the management regulations of the UCI, the file must be submitted for review to the CSSF.
The current procedures for prospectus changes requiring prior review or express authorisation remain unchanged and continue to apply in accordance with existing legal and regulatory frameworks.
This upcoming reform is expected to modernise regulatory processes, reduce administrative burdens, and enhance overall efficiency for market participants, while preserving the core principles of regulatory oversight and investor protection.
Should you require further information or assistance, our Investment Funds team would be pleased to support you.