White-label funds in Luxembourg: the CSSF requires a new form

On 8 October 2026, the CSSF published a communication to the investment fund industry together with a form for investment fund managers (IFMs, "GFI" in French) established in Luxembourg that manage, or plan to manage, "white-label" funds on behalf of third-party initiators. Compliance officers at the management companies concerned should prepare for this step before taking on any new activity of this kind.

White-label: a widespread model in the Luxembourg financial centre

According to the CSSF communication of 8 October 2026, a "white-label" fund is a vehicle initiated by a third party, such as a distributor, a private bank, a family office or a foreign promoter, but managed by an investment fund manager established in Luxembourg. The fund may carry the name of this third-party initiator, or the initiator may be appointed as the IFM's delegate for certain operational functions. This model allows a player without a management authorisation to launch a fund by relying on the regulatory infrastructure of an established Luxembourg IFM, a very common practice in the Grand Duchy's financial centre.

Why the CSSF is stepping up its supervision of conflicts of interest

The legal basis for this new obligation is the Law of 3 March 2026, which transposes European Directive 2024/927. This law inserted Article 13(2a) into the Law of 12 July 2013 on alternative investment fund managers and amended Article 111(2) of the Law of 17 December 2010 relating to undertakings for collective investment. According to the legal text, these provisions have applied since 16 April 2026. In the white-label model, the Luxembourg IFM remains solely accountable to the CSSF, while the third-party initiator often designs the product and takes a share of its revenue. This arrangement creates fertile ground for the conflicts of interest that the regulator now wants documented systematically.

The form: what must be sent to the CSSF

The form published by the CSSF, titled “Information to be provided to the CSSF by a Luxembourg-based IFM intending to perform white-label business under Article 13(2a) of the Law of 2013 and/or Article 111(2) of the Law of 2010”, is version 1.0 and comes as an Excel file of about 50 KB. It has three sheets:

• A sheet for identifying the IFM and for its declaration
• A detailed questionnaire on the business model, the fee structure and the governance of conflicts of interest
• An appendix listing the assets under management already taken on as part of a white-label activity

The CSSF states that it expects detailed explanations and evidence of compliance from the IFM, with particular attention paid to how conflicts of interest between the manager and the fund's third-party initiator are managed.

Who must notify, and when

According to the CSSF, the requirement applies to IFMs established in Luxembourg that manage, or plan to manage, a fund initiated by a third party, including where the fund carries the initiator's name or the initiator is appointed as the manager's delegate. The form must be submitted when the IFM first takes up this activity. The CSSF communication sets no explicit deadline, no specific filing channel and no formal approval stage, so each IFM has to work out the exact format of its notification before launching a new white-label activity. The regulator also reserves the right to request additional information at any time, even after the form has first been submitted. Further reading on this topic: DORA and third-country branches.

A regulatory clarification, not legal advice

This communication is a regulatory clarification issued by the CSSF, not legal advice. Management companies that already manage funds on behalf of third parties, or plan to do so, should seek the opinion of a lawyer specialising in investment fund regulation before making any notification, in particular to determine exactly where they stand under Article 13(2a) of the 2013 Law and Article 111(2) of the 2010 Law, and to prepare in advance the documentation the regulator expects on the business model, the fee structure and the governance of conflicts of interest.