New communication means for AIFM reporting as of 2 November 2023

The CSSF has introduced a new communication method for AIFMs starting on 2 November 2023. This initiative was developed collaboratively with industry pilot entities and aims to facilitate the submission of AIFM reporting using an API solution known as S3 technology.
As of 2 November 2023, AIFMs will have the option to utilize this newly established API solution for their AIFM reporting requirements. Furthermore, a dedicated webinar is scheduled for October to provide comprehensive insights and details regarding the implementation of this innovative reporting mechanism.
Of note, the traditional approach of transmitting AIFM reporting through external channels will continue to be accessible until 30 June 2024. This transitional period allows AIFMs to adjust to the new API-based reporting system and ensures a smooth transition.
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Furthermore, the CSSF issued a corresponding technical guidance which provides important information regarding AIFM reporting requirements. It highlights specific issues and provides instructions on how to address them.
One key requirement mentioned is the need for funds trading under MiFID to have a LEI code. This code is mandatory for such funds. Additionally, the document emphasizes the importance of accurately reporting the percentages of financing amounts. The sum of these percentages should be between 99% and 101%. If the sum falls below 99% or exceeds 101%, it is considered inconsistent and needs to be corrected.
Another important point is related to investment strategies. If there is no predominant AIF type and all investment strategy NAV percentages are the same, all investment strategies should be set as primary investment strategies. This flag should be true when the investment strategy code reported is equal to „MULT_PEQF“, „MULT_HFND“, or „MULT_REST“.
The document also provides guidance on reporting geographical focus and notice periods. The sum of percentages for geographical focus should be 100%, and the notice period reported should be consistent with the type of shares or units. If there are multiple classes of shares or units, the notice period reported should be the asset-weighted notice period.
Furthermore, the document addresses the reporting of financing liquidity profiles and historical risk profiles. The sum of percentages for financing liquidity profiles should be 100%, and the month rates for historical risk profiles should be consistent with the reporting period.