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

This affects IFMs planning to act as management company for funds sponsored or controlled by third parties, a model often used by alternative and UCITS managers to expand product ranges without full in-house distribution. For compliance teams, the key takeaway is that supervisory engagement must be proactive and evidence-based: firms should expect to demonstrate adequate substance, governance, risk management, delegation oversight, conflicts-of-interest controls, and operational resilience before launching or extending white-label mandates. The CSSF's information request is likely a pre-authorisation or pre-notification step, so early preparation is critical.

Firms should review their target operating model, document board and senior management responsibilities, map all delegated functions, and ensure AML/CFT and investor protection frameworks are robust. Budgeting for legal and regulatory advisory support is advisable. While not a surprise for Luxembourg fund managers, this guidance reinforces the CSSF's focus on substance over form in outsourcing and white-label arrangements.

Firms that can clearly evidence control and oversight may gain a competitive advantage in winning white-label mandates; those unable to demonstrate substance may face delays or supervisory pushback. No specific deadline is stated, but firms intending to start white-label activity should initiate dialogue with the CSSF well ahead of launch.