FAQ Crypto-Assets – Undertakings for collective investment (Updated)
AI Analysis
The CSSF has released Version 7 of its FAQ on Crypto-Assets for Undertakings for Collective Investment, updated on February 4, 2026, to reflect the entry into force of the Markets in Crypto-Assets Regulation (MiCAR). This guidance establishes binding investment limits, authorization requirements, and risk management standards for UCITS and AIFs investing in crypto-assets, fundamentally reshaping how Luxembourg-regulated collective investment schemes can engage with digital assets.
Key dates
- February 4, 2026
- - FAQ Version 7 effective date (entry into force of MiCAR alignment)
- July 1, 2026 Deadline
- - Deadline for Virtual Asset Service Providers (VASPs) to transition to CASP authorization or cease operations
- No specific implementation grace period
- - The FAQ does not specify a transition period for existing funds exceeding the 10% limit; firms should clarify this with the CSSF immediately
Suggested considerations
- *Immediate Compliance Steps:
- *Portfolio Audit: Conduct a comprehensive review of all UCITS and AIF holdings to identify current and potential crypto-asset exposures, both direct and indirect (including derivatives with crypto underlyings).
- *Investment Policy Updates: Revise fund documentation, prospectuses, and investment policies to reflect the 10% NAV limits and MiCAR compliance requirements.
- *Risk Management Assessment: Update risk management policies to address crypto-asset volatility, liquidity, and technological risks, with case-by-case impact assessments on fund risk profiles.
- *Investor Notification: Ensure transparent and timely communication with investors regarding any crypto-asset investments or policy changes.
- *CSSF Notification: UCITS envisaging crypto-asset investments must inform the CSSF of such plans in advance.
What changed
The most significant regulatory modifications in Version 7 include: Investment Limits for UCITS UCITS may invest indirectly in crypto-assets for a maximum of 10% of their net asset value (NAV). These indirect investments are limited to transferable securities that do not embed derivatives in accordance with Article 10 of the Grand-ducal Regulation of 8. Investment Limits for AIFs AIFs open to retail investors other than well-informed investors may invest in crypto-assets for a maximum of 10% of their NAV. However, AIFs may invest directly and indirectly in crypto-assets under MiCAR's scope, provided such investments do not prevent compliance with existing regulatory requirements. Authorization Requirements for Elevated Exposures Any AIFM intending to manage an AIF investing in crypto-as
Compliance impact
Urgency Rating: HIGH
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
What the CSSF said
Version 7 – 04/02/2026
Published by CSSF . Read the full notice at the source for the authoritative text.