A new regulatory environment for liquidity risk management.
The implementation of Directive (EU) 2024/927 — AIFMD II / UCITS VI — into Luxembourg law by the Law of 3 March 2026 has introduced enhanced liquidity-management requirements for Luxembourg UCITS and for Luxembourg-authorised AIFMs managing open-ended AIFs, applicable from 16 April 2026.
Under the new framework, UCITS and AIFMs managing open-ended AIFs must generally select at least two appropriate Liquidity Management Tools (LMTs) after assessing their suitability against the investment strategy, liquidity profile and redemption policy of the relevant fund. The selection cannot consist solely of swing pricing and dual pricing. Detailed activation and deactivation policies and operational arrangements must also be established and communicated to the CSSF.
Fiduciaire Beaumanoir’s specialised support :
Fiduciaire Beaumanoir assists investment funds, their governing bodies and their appointed service providers in translating these regulatory requirements into clear and workable governance arrangements.
Our intervention can include the review and preparation of:
LMT governance framework → selection rationale → written policies and procedures → corporate and fund documentation → operational responsibilities → board approval → service-provider coordination → CSSF communication and ongoing monitoring.
Our role is particularly designed to ensure that regulatory requirements are not treated merely as a formal documentation exercise, but are incorporated into the fund’s actual governance and control environment.
Liquidity Management Tools
The Luxembourg framework identifies, among others, the following Liquidity Management Tools:
Redemption gates · Extension of notice periods · Redemption fees · Swing pricing · Dual pricing · Anti-dilution levies · Redemption in kind, together with specific provisions concerning suspension of subscriptions/redemptions and side pockets.
Fiduciaire Beaumanoir can assist in documenting the rationale for the selected tools and coordinating the respective responsibilities of the fund, governing body, AIFM or ManCo, administrator, transfer agent, depositary and other parties involved.
From Regulation to Practical Implementation
Compliance with AIFMD II liquidity requirements requires more than inserting provisions into a prospectus.
An effective framework should demonstrate consistency between:
the investment strategy → portfolio liquidity → investor profile → redemption frequency → liquidity stress scenarios → selected LMTs → activation thresholds → operational implementation → governance and escalation procedures.
This is precisely where Fiduciaire Beaumanoir seeks to add value: bringing together regulatory requirements, governance documentation and operational reality.
The CSSF requires the selection of LMTs to be reflected in the relevant fund documentation and requires detailed activation/deactivation policies and procedures. The CSSF’s dedicated eDesk procedure also provides for the reporting of LMT selections and, where required, their activation or deactivation.
AIF — Dedicated Advisory
Is your Liquidity Management Framework ready?
Fiduciaire Beaumanoir assists Luxembourg investment structures with the governance and documentation required to address the new AIFMD II liquidity-management framework.
LMT selection and documentation · Policies and procedures · Governance review · Board documentation · Service-provider coordination · Fund-document review · CSSF reporting support · Ongoing governance monitoring
Talk to us about your fund.