Reporting according to Annex IV of Commission Delegated Regulation (EU) No 231/2013 supplementing Directive 2011/61/EU – Addition of new rules and updates of ESMA’s AIFMD Q&As

The CSSF has updated its technical guidance on AIFM reporting in light of the revised IT technical guidance introduced by ESMA in November 2023 (eventid=21637). The updated document, CSSF AIFM Reporting – Technical Guidance provides information on the different feedback files that senders of AIFM reporting receive and the CSSF’s checks on the reporting files. Notably, certain fields have been made mandatory in the revised guidance (please see below).
The CSSF technical guidance should be read in conjunction with the Periodic and non-periodic transmission of information by AIFMs instructions in the CSSF website, explaining the legal reporting encompassing all the periodic and ad hoc information to be transmitted to the CSSF for prudential supervisory purposes by the AIFMs under its supervision, observing the file transport and data protection instructions. Supervised entities are required to transmit periodic data relating to their activities to the CSSF, on a quarterly, half-yearly or annual basis, depending on the circumstances.
As a reminder, each AIFM must receive at least three positive feedback files before the necessary controls have been completed. The CSSF may contact the AIFM again at a later stage regarding the content of the reporting file(s). In case of problems with feedback files or error messages, the AIFM should inform their service provider and/or contact the CSSF exclusively at aifm_reporting@cssf.lu.
Additionally, the CSSF highlights the latest update to ESMA’s AIFMD Q&As (eventid=21576), particularly Section VII, which clarifies the rules on considering the leverage effect of exposures associated with financial structures controlled by AIFs that do not pursue a private equity strategy.
More specifically, the aforementioned CSSF AIFM reporting – Technical guidance was updated into Version 1.4 on 24 November 2023 with an Adaptation of chapter 4 – „Procedure to register as a sender“, section 4.1 „Application Programming Interface (API)“ on page 12. We would like to present the section in full, highlighting the new amendments in bold & italic, full quote after the break:
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##### 4.1 Application Programming Interface (API)
If you want to submit the AIFM reporting for a reporting entity you act on behalf via API, this link must be first registered at CSSF. To do so, please send an email at edesk@cssf.lu with the following information:
– The name and CSSF identification number of the sender
– In case of double licensing, please mention the CSSF identification number you’ll use to create the bucket
– The name and CSSF identification number (A-xxxx) of the reporting entity
you act on behalf
– Full name of a contact person
– Phone number of a contact person
– E-mail address of a contact person
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Furthermore, an adaptation of the M/C/O/F fields and alignment of the descriptions to the latest version of the ESMA technical guidance has taken place. Finally, a replacement of CAF-216, CAF-217, CAF-218 and CAF-219 by new CAF-216 (deactivated at CSSF) as well as a new CAF-217 (also deactivated at CSSF).