AIFM services, ManCo and private equity firm support in Luxembourg, accounting, reporting and substance.
Financial Services Luxembourg provides the back-office AIFM and ManCo services that Luxembourg management companies, GPs and private equity firms outsource: management company accounting, preparation of regulatory reporting data, substance file and governance. Regulated management and authorisation remain with the authorised AIFM. Financial Services Luxembourg supports accounting for eligible entities, subject to their classification and the licensed accountant's statutory thresholds. Official NAV calculation, UCI administration and reserved functions remain with appropriately authorised providers; legal advice and notarial acts are provided by qualified professionals.
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In Luxembourg, AIFM and ManCo services are the back-office functions that an alternative investment fund manager authorised or registered under the law of 12 July 2013, or a management company, outsources to a licensed accountant: bookkeeping and annual accounts, Annex IV reporting data and the substance file. Portfolio and risk management stay with the AIFM.
Law of 12 July 2013 on alternative investment fund managers (transposing the AIFM Directive 2011/61/EU), registration thresholds of article 3(2) of the Directive (EUR 100 million of assets under management, or EUR 500 million unleveraged with no redemption rights for five years), AIFMD II developments (Directive (EU) 2024/927); applicable CSSF circulars.
Key takeaway
- Financial Services Luxembourg provides the back office; regulated management and CSSF authorisation sit with the AIFM.
- AIFM services here means outsourced accounting of the management company, not the AIFM function.
- A private equity firm usually combines a GP, a carried interest vehicle and deal SOPARFIs.
- A RAIF requires a fully authorised AIFM; ManCo substance is a growing supervisory checkpoint.
Technical definitions and responsibilities
AIF (alternative investment fund)
An AIF is a collective investment undertaking that raises capital from a number of investors to invest according to a defined policy for their benefit and is not a UCITS. A vehicle is classified by its characteristics, not merely by its legal form.
AIFM (alternative investment fund manager)
An AIFM is the manager responsible for AIFMD management functions, notably portfolio and risk management as applicable. Its authorised or registered status is distinct from the status of a fund accountant, UCI administrator or depositary.
Further reading: RAIF, fund services, fund director and net asset value.
What do a licensed accountant's AIFM and ManCo services cover?
The AIFM function, portfolio management and risk management of an alternative investment fund, is an activity authorised by or registered with the CSSF. The AIFM and ManCo services described on this page are that management company's back office: corporate bookkeeping, annual accounts and RCS filing, preparation of the accounting data feeding Annex IV reporting, tracking of management fees invoiced to the vehicles, and the substance file (office, staff, decisions taken in Luxembourg).
Three functions stay outside this scope and are performed by separate professionals: regulated management itself, striking the net asset value of the funds, and the UCI administrator function within the meaning of CSSF Circular 22/811. The firm coordinates the interface with those providers, with the third-party AIFM in a ManCo hosting set-up, and with the fund accountant where the vehicle is eligible.
What a private equity firm in Luxembourg outsources
A private equity firm established in Luxembourg is not a single entity. The usual set-up has a GP, often a SARL, managing an SCSp; a carried interest vehicle owned by the investment team; and one or more deal SOPARFIs holding the investments. Each of these companies has its own annual accounts, tax returns, VAT and substance obligations.
These are the companies in the structure that Financial Services Luxembourg takes on, subject to their eligibility under the licensed accountant's scope: bookkeeping, annual accounts, tax returns, invoicing of management fees to the fund, corporate secretarial work for the GP and the annual substance file. Fees are published on the pricing page and a firm quote is issued within 48 hours. Governance of the vehicle is covered on the fund director page.
Authorised AIFM, registered AIFM or third-party ManCo: which framework for your structure?
Three frameworks are possible. The manager stays below the article 3(2) AIFMD thresholds, EUR 100 million of assets under management, or EUR 500 million unleveraged with no redemption rights for five years, and registers with the CSSF without full authorisation. The manager exceeds those thresholds or launches a RAIF, and must then be fully authorised. Or the sponsor appoints an authorised third-party management company to carry the AIFM function, ManCo hosting, and keeps only the GP and the holding companies.
The choice depends on asset size, investor base and fundraising timetable, and is a matter for legal advice. In all three cases the accounting needs of the GP, the carry vehicle and the SOPARFIs are the same, and the substance file of the Luxembourg management company becomes a recurring prudential checkpoint.
Who this is for
- Authorised and registered (sub-threshold) AIFMs
- UCITS management companies and ManCos
- Private equity firms: GP of an SCSp, carried interest vehicle, deal SOPARFIs
- Sponsors using a third-party AIFM (ManCo hosting)
What we do
- Management company accounting and annual accounts
- Regulatory reporting assistance (Annex IV, etc.)
- Substance: office, staff, documented governance
- Coordination with the CSSF, auditor and legal counsel
Outsourcing the back office of your AIFM, ManCo or private equity firm?
First reply within 24 working hours, from a named adviser. Firm quote within 48 working hours once the scope is defined. NDA on request before any confidential document.
Official sources and verification
This page is published under the editorial responsibility of Mickaël LOC for Financial Services Luxembourg (business permit 10077274). The rules cited should be checked against competent authorities and the circumstances of the case.
Frequently asked questions
Can you act as the AIFM?
No. Financial Services Luxembourg is not an authorised manager. We provide accounting support, reporting and substance, and coordinate with your AIFM or a third-party AIFM (hosting).
What is the difference between an AIFM and AIFM services?
The AIFM is the authorised or registered company that performs portfolio management and risk management for an alternative fund. AIFM services are the back-office functions that company outsources: accounting, annual accounts, reporting data, substance. Financial Services Luxembourg provides the latter, never the former.
What services does a private equity firm outsource in Luxembourg?
The bookkeeping and annual accounts of the GP, the carried interest vehicle and the deal SOPARFIs, the tax and VAT returns of each company, management fee invoicing, corporate secretarial work and the annual substance file. Managing the fund, valuing it and administering the vehicle stay with the authorised professionals.
Above which threshold must an AIFM be authorised?
Above EUR 100 million of assets under management, or EUR 500 million unleveraged with no redemption rights for five years, under article 3(2) of the AIFM Directive. Below that, the manager registers with the CSSF; a RAIF nevertheless requires a fully authorised AIFM whatever the amount.
Do you handle Annex IV reporting?
We assist with its preparation from accounting and portfolio data; the regulatory filing sits with the authorised AIFM.
What is ManCo hosting?
Using an authorised third-party management company that carries the AIFM function for your fund. We coordinate the operational interface with it.
Request a quote: AIFM / ManCo support
First reply within 24 working hours, from a named adviser. NDA on request before any confidential document.