AIFMD II & UCITS VI : Liquidity management tools

The two-LMT rule

All open-ended AIFs and UCITS are legally required to select and document at least two Liquidity Management Tools (LMTs) from a harmonised list of seven LMTs, such as swing pricing, redemption gates, anti-dilution levies, or side pockets.
The LMTs are divided into two categories: quantity-based and anti-dilution. It is recommended toapply at least one LMT from each category.

Disclosure

Fund documentation, including prospectuses and policies, must explicitly disclose the selected LMTs.

CSSF Reporting

The selected LMTs must be notified to the CSSF via eDesk.

What’s next

By 16 April 2027, more details must be provided on each LMT such as calculation methods and activation thresholds.
From 1 October 2027, stress testing and policies will strengthen LMT requirements.

Why the changes matter

The market is shifting from governance to evidence to ensure fair treatment of investors and financial stability.

How can Osmia Consulting help you?

With extensive experience in Luxembourg’s regulatory landscape, Osmia Consulting provides advisory and IT solut

At Osmia Consulting, we view regulation as a strategic enabler. When approached correctly, it strengthens organisations rather than constraining them.
Please get in touch to help you navigate the new requirements.