Delegation Is Not Outsourcing : Why accountability remains with the IFM
Delegating a function does not mean delegating responsibility.
For Luxembourg Management Companies and AIFMs, effective delegation goes far beyond contractual arrangements and periodic reporting. It requires meaningful oversight, sufficient internal expertise, the ability to challenge service providers and clear escalation procedures.
The real question is not “Who performs this function?” but rather “How do we demonstrate that we remain in control?”
In our latest publication, we explore the key elements of a robust delegation framework, the role of the Board and the importance of maintaining effective governance in an increasingly complex ecosystem of service providers.
Valuation in 2026 : The CSSF expectations are rising
Valuation is no longer just about producing a NAV.
As regulatory scrutiny intensifies, Luxembourg Management Companies and AIFMs are expected to demonstrate that their valuation processes are independent, robust, transparent and capable of withstanding challenge.
The CSSF’s increasing focus on valuation practices, combined with the evolving AIFMD II framework, reinforces a clear message: delegating a valuation activity does not delegate responsibility.
For managers of complex, private or less liquid assets, valuation governance is becoming a core element of investor protection, risk management and regulatory readiness.
Our latest article explores the key challenges and the practical steps firms should consider to strengthen their valuation framework.
AIFMD II & UCITS VI : Liquidity management tools
AIFMD II and UCITS VI are here — and while it does not overhaul the European framework, it introduces several important changes for asset managers and funds.
The revised directive strengthens, among other things, the liquidity risk management.
Benchmarking Compliance In 2026 : Insight Without Imitation
Benchmarking is widely used — and often misunderstood.
Best practices are not ready-made solutions. They are reference points, not blueprints.
Delegation In 2026 : Oversight Cannot Be Outsourced
Delegation remains essential for efficiency and expertise.
Responsibility, however, always remains with the delegating entity.
ESG Compliance In 2026 : From Narrative to Evidence
ESG is no longer a communication topic. It is a compliance discipline.
Compliance Culture In 2026 : Beyond Policies and Procedures
Policies, procedures and controls are essential. But they do not operate themselves.
In 2026, regulators increasingly assess how people behave, not just what documents say.
Data Governance In 2026 : The Silent Backbone of Compliance
Most compliance failures do not originate in legal interpretation.
They originate in inconsistent, incomplete or poorly governed data.
Operational Resilience : Built in Daily Operations, Not in Crisis Mode
Operational resilience is often discussed through extreme scenarios: cyber-attacks, system outages, market shocks.
But regulators know the truth: resilience is built — or weakened — in everyday operations.
Compliance Automation in 2026 : When Speed Meets Responsibility
Automation is no longer a differentiator. By 2026, it has become a baseline expectation.
Yet, many institutions confuse automation with control. Digitising a process does not automatically make it compliant — and in some cases, it can amplify weaknesses.
Regulatory In 2026 : From Compliance Burden to Strategic Advantage
For many financial institutions, regulation is still approached as a constraint — something to absorb, interpret, and survive.
But 2026 confirms a structural shift: regulation is increasingly shaping how institutions are organised, governed and managed.
Regulatory Retrospective 2025: A Transformative Year for the EU Financial Sector
2025 was a decisive year for EU financial regulation — from CRR3/CRD6 implementation to ESG refinement, digital resilience focus and the first wave of regulatory simplification initiatives.
Osmia Consulting looks back at the key developments that shaped the year and outlines what institutions should prepare for as we head into 2026.
Regulatory Simplification 2026: What Financial Institutions Should Expect
Regulatory simplification is becoming a major theme for 2026. From benchmark rules to reporting obligations and securitisation transparency, the EU is recalibrating the compliance landscape to reduce administrative burden while maintaining supervisory integrity.
In our new publication, Osmia Consulting explores what these simplifications mean in practice — and how firms can benefit from them without increasing regulatory risk.
EU Sustainable Finance in 2026: What to Expect from the Evolving EU Taxonomy
The EU Taxonomy is set for further refinement in 2026, with updated criteria, clarified DNSH expectations and stronger alignment with CSRD.
These changes will reshape how institutions classify activities, report sustainability information and design ESG-aligned products. In our latest insight, Osmia Consulting outlines what organisations should expect — and how to prepare effectively.
The EU Artificial Intelligence Act
Artificial intelligence is reshaping the financial industry — but with innovation comes regulation.
The EU Artificial Intelligence Act is the world’s first framework setting clear rules for trustworthy and responsible AI.
For financial institutions, the real question is: how can you stay compliant while still innovating with confidence?
Independent Directors: Brief analysis
In Luxembourg, Directors play a central role in shaping strategy, safeguarding governance, and ensuring compliance. But beyond legal requirements, Independent Directors bring something more: objectivity, expertise, and the ability to balance competing interests in a transparent and professional manner.
At Osmia Consulting, we believe that independent oversight is not just a regulatory box to tick – it is a driver of trust, resilience, and long-term success.
Delegation and Supervision: Are You Truly Able to Supervise Your Delegates?
Delegation has become a cornerstone of Luxembourg’s financial and corporate ecosystem. Portfolio management, distribution, central administration - almost everything can be delegated. But one thing never is: responsibility.
The CSSF has been clear - delegation does not remove the duty to supervise. And yet, in practice, effective oversight remains the exception rather than the rule. Too often, monitoring is passive, responsibilities are unclear, and evidence of actual supervision is missing.
Automating Compliance in 2025
Automation is everywhere in compliance agendas in 2025 - but is it always the right answer?
Regulatory complexity has reached a level where manual processes are no longer sustainable. Yet, with the proliferation of “miracle tools” and one-size-fits-all solutions, firms risk either over-investing in technology or relying on tools that fail to address their real needs.
CSSF 18/698 : 5 erreurs encore trop fréquentes en 2025
Depuis son entrée en vigueur, la Circulaire CSSF 18/698 constitue une pierre angulaire du cadre réglementaire luxembourgeois en matière de gestion d’actifs. Pourtant, en 2025, nous observons encore des erreurs récurrentes qui pourraient facilement être évitées.
The Future of Financial Regulation in the EU
At Osmia Consulting, we believe the regulatory landscape is undergoing a quiet but powerful transformation. In our latest article, "The Future of Financial Regulation in the EU", we explore the key trends shaping the next decade — from digital compliance and supervisory convergence to ESG accountability and governance.
Whether you're a compliance professional, legal advisor, or policy watcher, we invite you to read our perspective and join the conversation.