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Responsible Entities Auditors (REAs) and Undertakings for Collective Investment (UCIs): Requirements and Deadlines

This document outlines the requirements for Responsible Entities Auditors (REAs) and Undertakings for Collective Investment (UCIs) as per the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg.

Submission Deadlines

The following deadlines apply to submission of Self-Assessment Questionnaire (SAQ) and REA Report:

  • IFMs (Investment Fund Managers):
    • SAQ: 4 months after the end of the financial year (6 months for the first period)
    • REA Report: 7 months after the end of the financial year (9 months for the first period)
  • UCITS (Undertakings for Collective Investment in Transferable Securities):
    • SAQ: 3 months after the end of the financial year
    • REA Report: 5 months after the end of the financial year
  • Part II UCIs, SIFs, and SICARs:
    • SAQ: 4 months after the end of the financial year
    • REA Report: 6 months after the end of the financial year

First Reporting Periods

The following dates mark the start of the first reporting periods:

  • IFMs: Financial years ending on or after December 31, 2021
  • UCITS and Part II UCIs: Financial years ending on or after June 30, 2022
  • SIFs (Specialized Investment Funds) and SICARs (Sociétés d’Investissement Alternatif à Risque): Financial years ending on or after June 30, 2023

Additional Requirements for UCIs

UCIs must comply with the following additional requirements:

  • Modified Audit Opinions: Management must submit a letter to the CSSF explaining the rationale behind the modified opinion and its impact on the UCI and its investors.
  • Repealing Provisions: Circular 21/790 repeals Circular 02/81 and chapter P of Circular 91/75.

Responsibilities

REAs are responsible for:

  • Submitting SAQs and REA Reports
  • Preparing management letters (lettre de recommandation)
  • Determining significant weaknesses or areas of improvement
  • Following up on previous management letter issues

Specific Deadlines

The following deadlines apply to submission of specific documents:

  • Management Letters: 7 months after the end of the financial year for IFMs, 4 months for UCITS, and 6 months for Part II UCIs.
  • Letters Explaining Modified Audit Opinions: One month after publication of the annual report.

Overall, this document outlines the requirements for REAs and UCIs in terms of submitting SAQs, REA Reports, management letters, and other documents to the CSSF.