CSSF Data Collection on Commercial Real Estate for IFMs


In recent years authorities have started monitoring the influence of the real estate sector on financial markets more closely. To this effect the CSSF is now requesting Investment Fund Managers (IFMs) with an exposure to the real estate market to submit data on their commercial real estate activity bi-annually. In this context ‘commercial real estate’ is defined as follows:

“Commercial real estate means any income-producing real estate, either existing or under development, including rental housing; or real estate used by the owners of the property for conducting their business, purpose or activity, either existing or under construction; that is not classified as residential real estate; and includes social housing.”

Funds subject to the new reporting requirements are:

  • Luxembourg-based regulated or unregulated investment funds managed by an IFM (excluding UCITS set up under part I of the law dated 17 December 2010);

  • that have, according to their reporting, a predominant strategy defined as “Real Estate”;

  • that are neither funds of real estate funds (irrespective of the country of domiciliation of the target funds) nor feeder funds investing in a master domiciled in Luxembourg;

  • that have a direct or indirect exposure to the commercial real estate market.

For more information please visit the CSSF website.



For the first time data is due to be submitted on 30 September 2021, reporting on stock data ending on 31 December 2020 and on investment data over the second half of 2020.


As of 2022, data submission is due bi-annually, on 31 March and 30 September of each calendar year. The reporting due for March should refer to stock data ending on 31 December of the previous year and to investment data over the second half of the previous year. The reporting due for 30 September should refer to stock data ending on 30 June of the same year and to investment data over the first half of the same year.


Should your business have received communication from the regulator requesting data to be submitted and need help preparing the report, please get in touch.


OMEA Advisors can provide assistance in collecting, drafting, and submitting your data in line with the new requirements.