Luxembourg adopts the transposition law for AIFMD 2.0 and UCITS 6

27/03/2026

The Luxembourg law of March 3, 2026, transposing Directive (EU) 2024/927 amending the AIFMD 2 and UCITS 6 directives, was published in the Official Journal on March 9, 2026.

This process of transposing the directive into Luxembourg law began on October 3, 2025, with the submission of Bill 8628 to the Luxembourg Parliament. It aimed to amend the UCITS Act of December 17, 2010, as well as the Alternative Investment Fund Managers Act of July 12, 2013.

Submitted to the Chamber of Deputies, the Luxembourg bill followed the standard parliamentary legislative process. Approved by the Luxembourg Parliament on February 12, 2026, the law of March 3, 2026, was published on March 9, 2026, in the Official Journal.

This new Luxembourg law transposes Directive (EU) 2024/927, which amends Directives 2011/61/EU (AIFMD) and 2009/65/EC (UCITS) with regard to delegation arrangements, liquidity risk management, reporting for supervisory purposes, the provision of depositary and custody services, and the granting of loans by alternative investment funds.

Consequently, the Luxembourg Law of December 17, 2010, on Undertakings for Collective Investment, and the Law of July 12, 2013, on Alternative Investment Fund Managers, have been amended to reflect the new European framework.

The amended law takes effect on April 16, 2026, the deadline for all EU Member States to transpose AIFMD 2.0 into national law.

It should be noted, however, that the reporting obligations introduced by this directive will apply as of April 16, 2027. The law also provides for transitional and grandfathering provisions, particularly with regard to “loan-originating” alternative investment funds.

Jean-Pierre Gomez, Head of Public and Regulatory Affairs for SGSS Luxembourg