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Circular CSSF 26/912: What the Repeal of Circular IML 91/75 Means for Luxembourg UCI References
Circular CSSF 26/912 repealed Circular IML 91/75 with immediate effect on 22 May 2026. Compliance teams should therefore stop citing IML 91/75 as current authority, but they should not simply delete every control attached to it: each policy, board paper, due-diligence file and operating checklist must be mapped to the current Luxembourg, CSSF or EU source that now supports the underlying rule. This guide explains the status change, who should review legacy references and what evidence to retain.
On May 22, 2026, the CSSF published Circular CSSF 26/912. The circular repeals Circular IML 91/75, which concerned the revision and redesign of rules applicable to Luxembourg undertakings for collective investment. The CSSF also published a related communique on the repeal of Circular IML 91/75.
Direct Answer
If a document, checklist, article, or adviser note still cites Circular IML 91/75 as current Luxembourg UCI authority, treat that citation as needing review. Circular CSSF 26/912 repeals the older circular. That does not mean Luxembourg UCIs are outside supervision; it means readers should trace the current rule through the CSSF investment fund framework, the applicable law or regulation, and the current fund documentation.
| Reader situation | Practical response |
|---|---|
| You are reading an old fund memo | Check whether it still relies on Circular IML 91/75 and ask for the current source basis. |
| You manage a UCI compliance checklist | Remove stale reliance on Circular IML 91/75 and map each control to current CSSF, Luxembourg, or EU sources. |
| You are an investor comparing Luxembourg funds | Do not treat the repeal as a product-quality signal; use it as a reason to verify the current legal framework and official register entry. |
| You publish CSSF or fund-regulation content | Update pages that cite Circular IML 91/75 as live authority, and explain the May 22, 2026 repeal clearly. |
Key Dates
| Date | Event |
|---|---|
| May 22, 2026 | CSSF published Circular CSSF 26/912. |
| May 22, 2026 | CSSF published the communique on the repeal of Circular IML 91/75. |
| May 22, 2026 | Circular CSSF 26/912 entered into force with immediate effect, according to the circular text. |
| June 2, 2026 | This article checked the official CSSF source. |
Who Is Affected
The CSSF circular is relevant to readers who work with, publish about, or rely on Luxembourg undertakings for collective investment. That includes fund managers, UCI service providers, compliance teams, auditors, lawyers, fund boards, financial intermediaries, and investors reading older Luxembourg fund materials.
The most important affected audience is any team maintaining a control library, policy, due-diligence memo, marketing review checklist, or regulatory explainer that still cites Circular IML 91/75 without explaining that it has been repealed.
What Changed
Circular CSSF 26/912 changes the status of a historical UCI circular with immediate effect. The editorial consequence is straightforward: Circular IML 91/75 should not be presented as current authority after the repeal. Where the older circular appears in published content, update the citation, explain the repeal, and point readers back to the current CSSF investment fund regulatory framework.
This article does not replace a legal mapping exercise. A compliance team should identify the exact obligation it was using Circular IML 91/75 to support, then confirm the current source through CSSF, Luxembourg legal texts, EU measures where relevant, and qualified counsel or compliance advisers.
What Readers Should Check
Use this checklist when you encounter Circular IML 91/75 in a current-looking document:
| Check | Why it matters |
|---|---|
| Is the document dated before May 22, 2026? | It may predate the repeal and need updating. |
| Does the document say Circular IML 91/75 is still applicable? | That statement conflicts with Circular CSSF 26/912 and needs review. |
| Does the document identify the current legal source? | A repeal note is not enough if the practical rule still matters. |
| Is the document investor-facing? | Investors need a plain-English explanation, not only a citation change. |
| Is the document a compliance control? | Controls should map to live sources, not repealed instruments. |
How This Fits the Investment Fund Framework
The CSSF investment fund framework remains the official starting point for mapping Luxembourg fund regimes such as UCITS, Part II UCIs, SIFs, SICARs, AIFMs, and related fund-industry rules. The repeal of a legacy circular makes that framework more important, because it helps readers avoid treating an old citation as a complete current rule map.
For broader context, see CSSF investment fund regulatory framework in Luxembourg and Luxembourg CSSF rules tracker.
Source Review Status
Reviewed on June 4, 2026 against the official source URLs listed in this article. This publication batch excludes CSSF articles with official CSSF URLs that returned a non-200 HTTP status during the pre-publication check.
Official Sources
- CSSF: Circular CSSF 26/912
- CSSF: Repeal of Circular IML 91/75
- CSSF: Investment fund industry regulatory framework
Bottom Line
Circular CSSF 26/912 is a source-status change that matters because stale fund-law citations can mislead readers. If Circular IML 91/75 appears in current UCI materials, update the reference, identify the live source basis, and keep the reader focused on the practical question: what rule applies now, to which fund or actor, and from which official source?
Legacy-reference audit
| Where IML 91/75 appears | Review action | Evidence to retain |
|---|---|---|
| Compliance policy or control library | Identify the exact proposition supported by the old citation and map it to the current instrument; do not replace it with Circular 26/912 as though the repeal circular recreated the rule. | Before-and-after control mapping, source owner and approval record. |
| Board or delegate oversight material | Check whether the reference affects an active oversight step, delegation expectation or reporting statement. | Reviewed paper, current source and decision minute. |
| Due-diligence questionnaire or procedure manual | Replace stale authority while preserving any operational question that remains required under current law or CSSF practice. | Version history and rationale for keeping, changing or retiring each item. |
| Investor-facing or marketing content | Remove any suggestion that IML 91/75 remains in force and avoid implying that repeal reduced investor protection. | Publication update note and links to the current framework. |
Review boundary
Circular 26/912 confirms repeal; it is not a substitute source for every provision previously associated with IML 91/75. Where the replacement basis is unclear, record the unresolved mapping and obtain Luxembourg fund-law or compliance review before changing an active control.