Marina Lukoyanova (mebs): Navigating regulatory shifts in Luxembourg's fund landscape
Luxembourg’s fund industry is experiencing a period of rapid regulatory evolution. Under the CSSF’s supervision, fund managers of UCITS and AIFs must now adapt to stricter requirements in liquidity management, sustainability risk measurement, and valuation governance. Marina Lukoyanova, Risk Manager at MEBS, recently discussed the main developments shaping the market and how management companies can address them effectively.
Strengthened Liquidity Management Requirements
One of the most important regulatory updates concerns liquidity management. The upcoming AIFMD 2.0, entering into force on 16 April 2026, will require fund managers of UCITS and open-ended AIFs to implement at least two liquidity management tools (LMTs). The accompanying Regulatory Technical Standards (RTS) specify that one must be quantity-based, while another must be an anti-dilution tool such as swing pricing or an anti-dilution levy. In parallel, IOSCO has issued revised recommendations on liquidity risk management, emphasising governance, oversight, disclosure, and contingency testing. According to Lukoyanova, “responsible entities must ensure that any liquidity management tool can be activated promptly and in an orderly manner.” In practice, this entails extensive coordination between risk, valuation, and operational teams. What appears straightforward in regulation can translate into complex implementation projects involving documentation, IT readiness, and cross-departmental cooperation.
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“Clients today want more than compliance—they want clarity, strategy, and tools that make their frameworks truly robust.”
Integrating and Measuring Sustainability Risks
The second major focus is sustainability risk integration. The second phase of ESMA’s Common Supervisory Actionon sustainability risks and disclosures began in Q1 2024, with CSSF feedback expected in September 2025. Supervisors are assessing how sustainability considerations are embedded within governance, risk management, and remuneration policies. The CSSF has specifically called for clearer methodologies, indicators, and limits within risk management frameworks. Lukoyanova notes that data availability remains a key obstacle: “Most portfolio companies in private equity or unlisted debt do not publish consistent ESG information, so managers often rely on estimates or proxies, which introduces uncertainty.” Measuring and monitoring sustainability risks across alternative strategies therefore requires creativity, credible metrics, and ongoing refinement as regulatory expectations evolve.
Valuation Oversight and Client Adaptation
A third priority is valuation. The CSSF is expected to revise valuation guidelines in 2025–2026, focusing on stress scenario planning, model governance, and the clear separation of valuation and risk management functions. These measures aim to reinforce transparency and independence, particularly for illiquid assets such as real estate and private equity. From a client’s perspective, the main challenge lies in implementation. Setting up swing pricing or conducting contingency simulations involves numerous stakeholders and systems. As Lukoyanova explains, clients increasingly seek both strategic guidance and technical expertise—tools to conduct effective liquidity stress tests, define sustainability metrics, and design robust risk and valuation frameworks suited to their operational reality.