ELTIF Communiqué – Update of the existing ELTIF application questionnaire

The Commission Delegated Regulation (EU) 2024/2759 (hereinafter “Delegated Regulation”) relating to European long-term investment funds (“ELTIF”) has been published today, 25 October 2024, in the Official Journal of the European Union.

It enters into force on the day following its publication.

This means that new ELTIF applications must now fully comply not only with the provisions of Regulation (EU) 2015/760 of the European Parliament and of the Council of 29 April 2015 on European long-term investment funds (as amended), but also with those of the Delegated Regulation.

Existing Luxembourg-based ELTIFs that do not benefit from the grandfathering clause must make the necessary adaptations to comply with the provisions of the Delegated Regulation as soon as possible. Any significant changes must be notified to the CSSF.

The CSSF has updated the ELTIF application questionnaire to reflect the provisions of the Delegated Regulation. The relevant changes have mainly been made to sheet “5. REDEMPTIONS MATCHING”. The updated ELTIF application questionnaire must be used for all new applications submitted from the date of this communiqué. As stated in the communiqués of 15 December 2023 and 29 July 2024, the ELTIF application questionnaire  is intended to facilitate and therefore speed up new ELTIF applications. It is therefore very important that the questionnaire is completed with due care and diligence.

In light of the new provisions of the Delegated Regulation, it is also very important that the ELTIF prospectus includes appropriate and detailed information on the ELTIF’s liquidity arrangements.