The RC report, drafted from your own documents
Coming January 2027. The drafter for the RC's annual summary report in Luxembourg is being built for January 2027.
In Luxembourg the RC prepares a summary report at least once a year (Article 42(6) of CSSF Regulation 12-02, as replaced by Article 59 of CSSF Regulation 20-05). Keltes will draft it from the documents you already hold. Your firm submits it, never Keltes.
Where the duty comes from
Under Article 42(6) of CSSF Regulation 12-02, as replaced by Article 59 of CSSF Regulation 20-05 of 14 August 2020, the RC prepares the summary report at least once a year and sends it to the RR, the authorised management and the board. Under Article 42(7), the RR submits it to the CSSF within five months of the end of the financial year: "Le responsable du respect est tenu de soumettre annuellement à la CSSF le rapport de synthèse mentionné au paragraphe 6 ci-dessus portant sur l’année écoulée dans les cinq mois suivant la clôture de l’exercice social du professionnel." That duty does not apply to a Luxembourg investment fund whose Luxembourg management company submits the report.
From 10 July 2027, Article 11(6) of the AMLR adds that "the compliance manager shall submit once a year, or, where appropriate, more frequently, to the management body a report on the implementation of the obliged entity’s internal policies, procedures and controls drawn up by the compliance officer". Keltes reads the RC as the compliance officer and the RR as the compliance manager.
These are Keltes' readings of the stored texts, checked by AI readers and not reviewed by an independent practitioner; amendments after 2020 have not been checked. For a RAIF or an unregulated alternative investment fund, the report goes to the AED as the AED asks. Keltes drafts; your RC and your RR confirm, and Keltes signs, files and sends nothing.
What goes in, what comes out
You giveComing
Last year's report, this year's policy and risk assessment, your delegate questionnaires and the figures the report needs.
You getComing
A draft in Word, in your RC's name. Every statement about the law cites its article; every figure names its source. A list of what is still missing.
What is not yet verified
The CSSF sets the form of the report in Circular CSSF 24/854 and its guidance. Keltes holds the founder's copies of those texts, not retrieved from the CSSF by Keltes and not yet verified, so this page says nothing about the form of the report, how the five months are counted or how the report reaches the CSSF. For RAIFs and unregulated alternative investment funds, Keltes has stored the AED's pages on the RC's report; its reading of them is not yet verified. For Belgium, where Keltes understands that the AMLCO writes a yearly activity report, the texts are stored but Keltes' reading of them is not yet verified, and a drafter is planned after the Luxembourg one.
Writing this year's report?
Write with your entity type and financial year end, and you will hear when the drafter is ready for your type of firm.