CSSF Policy Statements

Key dates

2026-05-11

European Commission published its report on the adequacy of the MMFR and identified market-resilience WLA levels of 20% for VNAV MMFs and 40% for public debt CNAV and LVNAV MMFs.

2026-06-08

CSSF launched its consultation on Guidance on Money Market Fund Weekly Liquid Asset Levels.

2026-08-03 Deadline

Deadline for stakeholders to submit responses to the CSSF consultation.

2026-10-30

CSSF published the IMMFA consultation response and final guidance, and announced a three-month implementation period.

Suggested considerations

• Firms should classify each affected MMF by VNAV, public debt CNAV or LVNAV status and map the applicable 20% or 40% WLA resilience benchmark against the existing 15% or 30% MMFR minimum.
• MMF managers should update liquidity-risk policies, escalation thresholds, management information and governance records to evidence enhanced vigilance when WLA approaches or falls below the relevant benchmark.
• Risk teams should incorporate the 20% and 40% benchmarks into Article 28 MMFR stress-testing and assess whether investor concentration, redemption behaviour, market liquidity and portfolio composition require liquidity materially above the benchmark.
• Firms should establish controls to identify periods exceeding 10 business days below the applicable benchmark and procedures for timely CSSF notification, including documented explanations, justifications and any relevant Article 28(4) or (5) remedial measures.
• Boards and senior management should review whether the three-month implementation period announced by CSSF requires changes to investment guidelines, liquidity buffers, breach escalation and reporting calendars.
• Compliance teams may wish to document that the resilience benchmarks are supervisory reference points rather than replacements for the MMFR statutory ratios, while recognising the CSSF’s stated intention to increase supervisory engagement for prolonged deviations.
• Firms should monitor cross-border consistency with the parallel supervisory approaches of the French AMF and Central Bank of Ireland, particularly where groups manage MMFs in multiple EU jurisdictions.

What changed

The CSSF has finalised guidance, following the consultation that closed on 3 August 2026, with only slight clarifications. MMF managers are expected to incorporate 20% WLA for VNAV MMFs and 40% WLA for public debt CNAV and LVNAV MMFs into liquidity-risk frameworks and Article 28 stress-testing processes. These benchmarks sit above the existing Regulation (EU) 2017/1131 minimum WLA requirements of 15% for VNAV MMFs and 30% for public debt CNAV and LVNAV MMFs.

Key dates

2026-08-03 Deadline

Deadline for stakeholders to submit responses to the CSSF consultation on the proposed MMF WLA guidance.

2026-10-30

CSSF published the final MMF WLA guidance, feedback statement and consultation responses, including ALFI’s response.

Suggested considerations

• Firms should classify each in-scope MMF as VNAV, public debt CNAV or LVNAV and map the applicable 20% or 40% WLA resilience benchmark against the fund’s existing 15% or 30% MMFR minimum.
• MMF managers should review liquidity risk-management frameworks, redemption assumptions, escalation thresholds, governance documentation and management-information reporting to demonstrate how the relevant benchmark is considered as a risk-management reference point rather than treated automatically as a statutory minimum.
• Managers should incorporate the 20% and 40% benchmarks into Article 28 MMFR stress-testing methodology, scenario analysis and board or governing-body reporting, while documenting fund-specific reasons for maintaining lower or higher WLA levels where appropriate.
• Firms should establish reliable daily monitoring of WLA, a process for identifying periods exceeding 10 business days below the relevant benchmark, and controls for escalating prolonged or substantial deviations to senior management and the CSSF.
• Compliance teams may wish to prepare the information expected in a CSSF notification, including the duration and magnitude of the deviation, its cause, investor and redemption characteristics, stress-test results, liquidity-management actions and the rationale for the manager’s response.
• Boards and depositaries should review whether oversight records, challenge processes and valuation or liquidity controls adequately address the potential supervisory consequences of persistent benchmark breaches.
• Firms should assess the interaction with Circular CSSF 26/911 and the 2025 ESMA MMF stress-test guidelines, which apply to CSSF-supervised MMFs and Luxembourg managers from the 30 June 2026 reporting date onward.
• Managers should avoid presenting the resilience benchmarks to investors as amended legal minimums unless the fund’s governing documents, disclosures or risk limits separately require that treatment; market commentary from respondents indicated concern that the 10-business-day trigger could operate as a de facto limit in practice.

What changed

The final guidance retains the European Commission’s market-resilience WLA benchmarks: 20% for VNAV MMFs and 40% for public debt CNAV and LVNAV MMFs. These levels sit above the Money Market Funds Regulation (Regulation (EU) 2017/1131) minimum WLA requirements of 15% for VNAV MMFs and 30% for public debt CNAV and LVNAV MMFs; the existing daily liquid asset minimums remain 7.5% and 10%, respectively.