Investment fund services in Luxembourg, accounting, reporting and substance.
Financial Services Luxembourg maintains the books of your Luxembourg vehicle and prepares the inputs required for the net asset value calculation. The manager, GP or AIFM, signs off the valuation and approves the final NAV. Around that engagement, we are your single point of contact: we coordinate the AIFM, the depositary, the approved statutory auditor and the notary, and every regulated act is performed by the licensed professional. As an authorised accountant and authorised fiduciary, business permit 10077274, the firm is not an authorised manager, a depositary, nor a UCI administrator authorised by the CSSF.
Investment fund services cover the accounting and operational work that surrounds a Luxembourg vehicle: bookkeeping, preparation of valuation inputs, investor and limited partner reporting, capital calls and distributions. They are distinct from the central administration function, which requires prior CSSF authorisation, and from portfolio management.
In Luxembourg, a fund's central administration and accounting function sit within the vehicle and its framework: the RAIF law of 23 July 2016, the SIF law of 13 February 2007, the SICAR law of 15 June 2004, and the AIFM law of 12 July 2013, under which an authorised AIFM (or a registered AIFM below the thresholds) and, for the relevant product regimes (RAIF, SIF, SICAR, Part II), a depositary may be required depending on the fund's regime and assets under management. The SCSp was introduced by the law of 12 July 2013. Financial Services Luxembourg acts as an authorised accountant and authorised fiduciary (business permit 10077274), subject to AED supervision for AML/CFT purposes: we maintain the vehicle's books and prepare the valuation inputs, without substituting for the authorised AIFM, the depositary, the approved statutory auditor or the central administrator. The UCI administration function, which covers register keeping, NAV calculation and client communication, requires prior CSSF authorisation under Circular 22/811 as amended by Circular 25/900.
Key takeaway
- What we deliver: accounting for the vehicle and its SPVs, preparation of valuation inputs, investor and LP reporting, capital calls and distributions, coordination of service providers.
- Financial Services Luxembourg keeps the vehicle's books; management (AIFM or ManCo), asset custody (depositary) and central administration are performed by authorised entities.
- The NAV is the cornerstone: we prepare its inputs, the manager signs it off and approves it.
- Luxembourg is Europe's leading fund centre; a rigorous back office is the condition for LP trust.
- Vehicles covered: RAIF, SIF, SICAR, SCSp/SCS and the intermediate SOPARFIs of a two-tier structure.
- Fees on a quote basis, tailored to the vehicle, the number of positions and the NAV frequency.
Which service providers are mandatory for a Luxembourg fund?
A RAIF, a SIF, a SICAR and a Part II UCI all require an AIFM and a Luxembourg depositary. An SCSp that stays below the article 3 thresholds requires neither.
| Vehicle | AIFM and Luxembourg depositary | Central administration authorised by the CSSF |
|---|---|---|
| RAIF | Mandatory | Yes, if outsourced |
| SIF | Mandatory | Yes |
| SICAR | Mandatory | Yes |
| Part II UCI | Mandatory | Yes |
| SCSp below the article 3 thresholds | Not required | Not required |
| SOPARFI or intermediate SPV | Not applicable | Not required |
| Unauthorised securitisation company | Not applicable | Not required |
What do investment fund services cover?
Fund administration refers to all the operational and accounting functions that keep an investment vehicle running day to day. Where management decides what to invest in and the depositary holds the assets, administration keeps the books, calculates the value of units, tracks every investor and produces the statements without which a fund can neither subscribe, distribute nor close. It is the back office on which everything else rests.
In practice, administration covers five main building blocks: fund accounting (keeping the books of the vehicle and its SPVs), net asset value (NAV) calculation, register keeping (tracking investors and unit movements), reporting to investors and limited partners, and the mechanics of capital flows, capital calls on one side, distributions on the other.
In Luxembourg, these functions sit within a precise framework. For an alternative fund, the AIFM law of 12 July 2013 may require an authorised AIFM (or a registered AIFM below the thresholds) and, for the relevant product regimes, a depositary, depending on the fund's regime and assets under management; and, where a UCI outsources its central administration to a third party, that delegate must be authorised by the CSSF. Financial Services Luxembourg does not operate at that level: the firm keeps the vehicle's books and prepares valuation inputs, without substituting for the AIFM, the depositary, the approved statutory auditor or the central administration.
This division of roles goes well beyond legal drafting: it protects investors by separating those who decide, those who hold and those who account. Understanding that separation is understanding why a rigorous, independent administrator earns its place in the budget rather than weighing on it.
Luxembourg, Europe's leading fund centre
It is no accident that so many funds choose Luxembourg. The country is Europe's leading investment-fund domicile and the second largest in the world, behind only the United States. That market depth translates into something practical: a complete ecosystem, AIFMs, depositaries, auditors, lawyers, administrators, can be mobilised immediately around your vehicle.
For a sponsor, this ecosystem translates into concrete advantages: a stable, recognised regulatory framework, a European passport for alternative funds marketed to professional investors, a multilingual workforce used to international standards, and a chain of providers familiar with the demands of the most exacting LPs.
But this maturity comes with a counterpart: expectations are high. Institutional investors, funds of funds, family offices and pension funds expect flawless administration, NAVs produced on time, clear reporting and full traceability. The Luxembourg market stands out precisely for this demand for quality.
It is in this context that the value of a trusted local accountant lies. Choosing Luxembourg means choosing a standard; you still need a chain of providers able to hold it cycle after cycle. Within that chain, Financial Services Luxembourg holds a precise place: the accountant of the vehicle, supplying the AIFM, the depositary and the approved statutory auditor with clean, reconciled and defensible data.
Vehicles covered: RAIF, SIF, SICAR, SCSp
The administration we provide covers the main vehicles of the Luxembourg toolbox. The RAIF (reserved alternative investment fund, law of 23 July 2016) has become the flagship vehicle for private equity, debt and real estate strategies: it requires no direct CSSF authorisation but mandates an authorised AIFM, allowing a fast launch while retaining the market's indirect supervision.
The SIF (specialised investment fund, law of 13 February 2007) remains popular for broader strategies reserved for well-informed investors, under direct CSSF supervision. The SICAR (investment company in risk capital, law of 15 June 2004) specifically targets venture capital and private equity, with a tax regime suited to that asset class.
The SCSp (special limited partnership, introduced by the law of 12 July 2013) is Luxembourg's equivalent of the Anglo-Saxon limited partnership. Without separate legal personality, tax-transparent and highly flexible contractually, it has become the structure of choice for private equity funds and their LPs. Its administration requires fine tracking of capital accounts and the waterfall.
Beyond the fund itself, we also keep the books of the intermediate SOPARFIs and SPVs that make up a two-tier structure, as well as securitisation vehicles. Administering a fund does not stop at the top vehicle: it runs all along the holding chain, down to the underlying assets.
Fund accounting: keeping the vehicle's books
Fund accounting is the foundation of all administration. Keeping the books of an investment vehicle is not simply about posting entries: you must track commitments and capital calls investor by investor, value a sometimes illiquid portfolio, handle flows between the fund and its SPVs, and produce accounts that will withstand both the audit and the scrutiny of LPs.
We keep these books in Lux GAAP or IFRS, depending on the fund documents and your investors' expectations, and at the level of each entity in the structure, from the top fund down to the underlying SPVs. This granularity is essential: it is what makes a reliable NAV calculation and consistent investor reporting possible at the end of the chain.
Well-kept fund accounting is also reconciled accounting. We systematically reconcile our figures with the depositary and with bank statements, so that no discrepancy remains when a NAV is struck or a distribution prepared. This reconciliation discipline is the best protection against costly errors.
Finally, this accounting is built for the close from day one. Throughout the year, we document positions, valuations and flows so as to present the auditor with a complete, orderly file. The annual close then stops being a race against time and becomes the simple formalisation of work already done.
Net asset value (NAV) calculation
NAV calculation is the cornerstone of fund administration. The NAV is the fund's net asset value divided by the number of units in circulation: it sets the price at which investors subscribe and exit, and the basis on which fees and distributions are calculated. An accurate NAV, on time, is non-negotiable.
Producing a NAV means first valuing the portfolio. For a private-asset fund, this means incorporating the valuations of the holdings, often established under agreed methodologies (fair value, valuation models), adding cash, deducting accrued expenses, management fees and any provisions, before allocating the result across the share classes.
The calculation frequency depends on the fund documents: monthly, quarterly or semi-annual for most private-asset funds, at the cadence required by your AIFM and investors. Whatever the cadence, we apply a stable production and validation circuit, with internal controls and reconciliation with the depositary before release.
The NAV carries a commitment of trust towards investors. That is why we produce it through a documented, traceable and auditable procedure. Should an LP or the auditor raise a question, every component of the NAV can be reconstructed and justified, with no grey areas.
The investor register: who keeps it, and when
Behind every vehicle there are investors, and behind every investor a register. Two situations are routinely conflated here. The registrar agent function of an undertaking for collective investment is a reserved activity, performed by a professional of the financial sector authorised by the CSSF. Keeping the register of partners of a common-law company, an SCSp or a SOPARFI, is a corporate secretarial act that requires no authorisation.
This function is more delicate than it appears in a private-asset fund. Investors do not simply buy units: they make commitments drawn down progressively, see their accounts moved by calls and distributions, and may transfer their position on a secondary market. The register must reflect this shifting reality at all times.
We keep this register with the rigour of a clerk's office: every movement is documented, dated and reconciled with the corresponding financial flows. It is this rigorous record-keeping that allows us, at any moment, to know each investor's exact position and produce reliable individual reporting.
The register is also the entry point for investor compliance. It is at the moment of entry in the register that identification (KYC) and AML checks take place; more on that below. Register and compliance thus form a single continuum, serving the security of the fund and its holders.
Investor and limited partner reporting
A fund also lives through the quality of the relationship it maintains with its investors, and that relationship runs through reporting. Limited partners expect clear periodic statements: their capital account (commitment, capital called, capital distributed, residual value), the fund's performance, the evolution of the NAV and the detail of the flows concerning them.
We produce these statements in the format and at the cadence set by the fund documents, ensuring each investor receives individualised, accurate and readable information. For a private equity fund, the capital account statement is often the most scrutinised document: it must reflect each LP's position to the cent.
Beyond raw figures, good reporting tells a coherent story: it links capital calls to the investments made, distributions to the disposals, and the NAV to the portfolio valuation. This overall consistency is what reassures institutional investors and strengthens the sponsor's credibility.
Finally, we produce the required regulatory reporting in coordination with your AIFM, which remains responsible for it before the CSSF. Our role is to provide clean, structured accounting data on which that regulatory reporting can rely with confidence.
Capital calls and distributions: the mechanics of flows
In a closed-end private-asset fund, capital is not paid in one go: it is committed and then drawn down progressively, in line with investments. Handling capital calls means determining, for each period, the amount to call from each investor in proportion to their commitment, issuing the call notices and tracking receipts.
At the other end of the cycle come distributions. When the fund realises a disposal or receives income, it returns capital and gains to investors in a precise order, the waterfall: return of called capital, preferred return (hurdle), manager catch-up, then sharing of the surplus (carried interest). Calculating this waterfall correctly is a technical, high-stakes operation.
We take charge of this mechanism end to end: calculating calls and distributions, applying the waterfall defined in the fund documents, updating capital accounts and producing the corresponding notices. Every operation is documented and reconciled, so that each investor's position remains accurate at all times.
It is often on this flow mechanics that an administrator's quality is judged. A mis-calculated capital call or a mis-applied waterfall immediately erodes LP trust. Our method, rigorous and traceable, is designed precisely so that these sensitive operations run without a hitch.
Investor AML / KYC and compliance
An investor's entry into a Luxembourg fund is never a mere registration: it comes with know-your-customer (KYC) and anti-money-laundering (AML) obligations. Identifying each investor, understanding the source of funds and documenting due diligence are an integral part of serious administration.
Financial Services Luxembourg, a licensed accountant subject to AED supervision for AML/CFT purposes under the AML framework (law of 12 November 2004), builds and verifies investor KYC files and keeps them up to date. For an undertaking for collective investment, those files are passed to the appointed registrar and transfer agent, a function reserved to a professional authorised by the CSSF.
This compliance does not conflict with fluidity: well organised, it avoids blockages at subscription and distribution time, and protects the fund, its AIFM and its depositary from regulatory and reputational risk. Administration that neglects AML exposes the whole edifice.
Ultimate regulatory responsibility remains with the AIFM and the fund's governing bodies; our role is to provide rigorous operational execution and the documentation that supports it. We work hand in hand with your manager so that investor compliance is a given, not a source of anxiety.
Coordination with the AIFM, depositary and auditor
A Luxembourg vehicle splits its functions across four actors: the AIFM manages the portfolio and risks, the depositary safekeeps the assets and controls the flows, the approved statutory auditor certifies the annual accounts, and the vehicle's accountant keeps the books and supplies the data to the other three. The quality of the fund depends on getting this coordination right.
With your management company (AIFM / ManCo), we exchange continuously: the NAV validation circuit, call and distribution instructions, data needed for regulatory reporting. Our clean accounting is the raw material from which the AIFM fulfils its own obligations towards the CSSF.
With the depositary, reconciliation is permanent: our accounting and cash positions are compared with those it holds, to ensure no discrepancy remains. This double check, administrator on one side, depositary on the other, is one of the structural safeguards of the Luxembourg model.
With the approved statutory auditor, finally, we prepare an orderly close file documenting positions, valuations and flows. The more rigorous our day-to-day record-keeping, the smoother the audit. Financial Services Luxembourg thus sits at the operational junction between these parties: one point of contact on the accounting side, every reserved act still performed by the licensed professional.
Who does what: the responsibility matrix
Role delimitation is not boilerplate: it conditions the compliance of the structure. On the fund's books, the firm prepares and maintains, the AIFM supervises within its own obligations, the depositary reconciles positions and the approved statutory auditor reviews at closing. On NAV work, the firm prepares the calculation files and supporting statements, the AIFM approves them under the valuation process set out in the fund documents, the depositary reconciles, the auditor audits.
On the investor register, Financial Services Luxembourg keeps the register of partners of common-law vehicles; for a UCI, register keeping belongs to the authorised registrar agent designated in the fund documentation. On investor AML/KYC, the firm provides documentary and collection support; regulatory responsibility for the framework sits with the AIFM or the GP depending on the applicable regime. On capital calls and distributions, the firm prepares the data and notices; the AIFM or GP authorises; the depositary controls the flows where the product regime requires it.
One structural boundary, finally: for vehicles subject to a CSSF-supervised product regime (SIF, SICAR, Part II), the central administration function in the regulatory sense belongs to actors authorised for that purpose. Financial Services Luxembourg acts as an authorised accountant (business permit 10077274) on the accounting work compatible with its authorisation, and slots into the authorised set-up where the vehicle's regime requires it. The exact scope is set out in writing in the mandate, function by function.
What we do and what we coordinate
It is important to be precise about our role, because that clarity protects your vehicle. Financial Services Luxembourg is an authorised accountant and authorised fiduciary (business permit 10077274), subject to AED supervision for AML/CFT purposes. We maintain the books of your vehicle, prepare the inputs required for the NAV calculation, produce investor reporting, prepare capital calls and distributions, and keep the register of partners of common-law vehicles.
What we are not, and do not claim to be, falls within distinct regulated functions. We are not the authorised AIFM that assumes portfolio management and regulatory responsibility; we are not the depositary that holds the assets; we are not the auditor that certifies the accounts. For these functions, we coordinate with authorised third parties and our network of partners.
Likewise, the vehicle's CSSF authorisation, where required, and notarial acts fall to the CSSF and our notary and lawyer partners. This division is not a limitation: it is the guarantee that each engagement is carried by the duly empowered party, in the investors' interest.
Within this whole, Financial Services Luxembourg is your point of contact on the operations and accounting side. You keep a single, multilingual and responsive contact who keeps your vehicle's books day to day and coordinates the chain around it. It is this combination of technical rigour and proximity that defines our approach to fund services.
Taking over the accounting of an existing vehicle
You do not have to launch a fund to call on us: we also take over the accounting of existing vehicles whose sponsor is no longer satisfied with the back office. An unresponsive provider, late reporting cycles, confused statements or errors on capital accounts are all legitimate reasons to switch.
The handover is organised in parallel, without service disruption. We retrieve the latest NAV, the financial statements, the investor register and the KYC files from the outgoing administrator, then configure your vehicle in our systems while reconciling each position. The goal is that no NAV cycle is missed during the transition.
This migration calls for close coordination with your AIFM and your depositary, which validate the switch. We frame the schedule, document each position taken over and ensure that the first NAV struck from our accounts is perfectly reconciled and defensible.
Changing accounting provider is, like any change of provider, simpler than it appears once it is methodical. We carry the process so that the transition is, for your investors, perfectly invisible: same deadlines, same quality, simply a stronger back office.
How much do investment fund services cost?
There is no single fund-administration price, and you should be wary of anyone who quotes one without knowing anything about your vehicle. The cost depends on several parameters: the type of vehicle (RAIF, SIF, SICAR, SCSp), the number of SPVs to keep, the number of positions and investors, the NAV calculation frequency and the complexity of the waterfall.
That is why our fees are set on a quote basis, tailored to the vehicle and the number of positions. This approach is not a reluctance to show prices: it is the only honest way to price an engagement whose real workload depends on the structure. A single-asset RAIF with a quarterly NAV and a multi-SPV fund with monthly reporting do not carry the same administration cost.
Our quote clearly distinguishes the components, vehicle accounting, NAV input preparation, register keeping, investor reporting, so that you understand exactly what you are paying for. This transparency also lets you make trade-offs, for example on NAV frequency, fully informed.
In practice, after a first conversation and a review of your fund documents, we provide a structured, readable quote quickly. You then know precisely what back office you are getting, and at what price, before any commitment.
Who does what in a Luxembourg fund
| Function | Role | Who performs it |
|---|---|---|
| Vehicle accounting | Bookkeeping, valuation inputs, reporting | Financial Services Luxembourg (authorised accountant) |
| Central administration | NAV sign-off, register, client communication | Entity authorised by the CSSF |
| Management (AIFM / ManCo) | Portfolio and risk management | Authorised AIFM (third party / partner) |
| Depositary | Asset custody, cash-flow monitoring | Authorised depositary bank |
| Audit | Certification of the annual accounts | Approved statutory auditor |
| Authorisation & reserved acts | CSSF authorisation, notarial acts | CSSF, partner notaries & lawyers |
Sources: official texts cited on this page. Summary: Financial Services Luxembourg, licensed accountant.
Who this is for
- Sponsors and managers of PE, VC, private debt and real estate funds
- GPs and AIFMs registered below the article 3(2) thresholds, for the accounting of their vehicle
- Family offices structuring a dedicated investment vehicle (RAIF, SCSp)
- Unregulated vehicles seeking a more responsive accounting back office
- Foreign sponsors opening a Luxembourg vehicle and needing a trusted local partner
What we do
- Fund and underlying SPV accounting (Lux GAAP, IFRS) and bookkeeping
- Preparation of the inputs required for the net asset value calculation, at the frequency set by the vehicle's documents
- Maintaining the register of partners of common-law vehicles, as a corporate secretarial act
- Investor and LP reporting: capital accounts, performance statements, periodic reports
- Handling of capital calls and distributions, including waterfall calculations
- Investor AML / KYC and regulatory reporting, in coordination with the AIFM
- Coordination with the management company (AIFM / ManCo), depositary and auditor
Estimated timelines
Pricing indication
Indicative ranges, excluding 17 % Luxembourg VAT, disbursements and filing fees. Firm quote after scoping.
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Preparation checklist
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The process, step by step
Scoping and onboarding of the vehicle
We review the fund documents (PPM, articles, LPA, subscription agreement) to understand the mechanics of the vehicle: investment policy, share classes, NAV frequency, waterfall and distribution rules. If the fund already exists, we organise the handover from the outgoing administrator, without service disruption.
Accounting set-up and configuration
We configure the chart of accounts for the fund and its SPVs, the share classes, valuation conventions and reporting templates. We calibrate the automations, access rights and internal controls to make the NAV calculation reliable from the very first cycle.
Accounting production and reporting
At each period, we keep the books, prepare the valuation inputs and produce investor statements (capital accounts, reports, distributions). The figures are reconciled with the depositary, then the manager signs off the valuation and approves the final NAV.
Capital calls, distributions and close
We prepare capital calls and distributions in line with the waterfall, maintain the register of partners of common-law vehicles and assemble the annual close files for the approved statutory auditor. You keep clear visibility on each investor's position throughout the life of the vehicle.
Official sources and verification
This page is written and reviewed by Mickaël LOC, licensed accountant in Luxembourg (business permit 10077274). The rules cited can be checked with the competent authorities.
Frequently asked questions
What is the difference between fund services and fund administration?
UCI administration covers three reserved functions: register keeping, NAV calculation and accounting, and client communication. Appointing an entity to perform them requires prior CSSF authorisation. The fund services we deliver are the accounting and operational work surrounding the vehicle, without performing those reserved functions.
Is Financial Services Luxembourg an AIFM or a depositary?
No. Financial Services Luxembourg is an authorised accountant (business permit 10077274) that keeps the vehicle's books, prepares the inputs for the NAV calculation and produces investor reporting. Portfolio management is performed by the authorised AIFM, asset custody by the depositary, and UCI administration by an entity authorised by the CSSF; we coordinate with them.
Which fund vehicles do you cover?
RAIF (law of 23 July 2016), SIF (law of 13 February 2007), SICAR (law of 15 June 2004) and SCSp (law of 12 July 2013), as well as the intermediate SOPARFIs and SPVs of a two-tier structure and securitisation vehicles.
What is the NAV and how often is it struck?
The NAV (net asset value) is the fund's net assets divided by the number of units: it sets the price of subscriptions, redemptions and distributions. We prepare the inputs at the frequency set by the fund documents, usually monthly, quarterly or semi-annually for private-asset funds, with reconciliation against the depositary; the manager signs off the valuation and approves the final NAV before release.
Can you handle capital calls and distributions?
Yes. We calculate capital calls in proportion to commitments, issue notices, track receipts, then process distributions per the waterfall defined in the fund documents (return of capital, hurdle, catch-up, carried interest) and update the capital accounts.
Do you keep the investor register?
It depends on the vehicle. For a common-law company, an SCSp or a SOPARFI, we keep the register of partners: this is a corporate secretarial act requiring no authorisation. For an undertaking for collective investment, the registrar agent function is reserved to a professional of the financial sector authorised by the CSSF; we do not perform it and we coordinate with the appointed provider.
Do you handle investor AML / KYC?
We provide the operational support. As an authorised fiduciary subject to AED supervision for AML/CFT purposes under the AML framework, we build and verify investors' KYC files and keep them up to date. Ultimate regulatory responsibility remains with the AIFM and the fund's governing bodies.
Can you take over the accounting of an existing fund?
Yes. We take over the bookkeeping from the outgoing provider without service disruption: retrieval of the latest NAV, financial statements, register and KYC files, configuration and reconciliation of each position, in coordination with your AIFM and depositary, so that no NAV cycle is missed.
How much do investment fund services cost?
Fees are set on a quote basis, tailored to the vehicle (RAIF, SIF, SICAR, SCSp), the number of SPVs and positions, the number of investors and the NAV calculation frequency. After reviewing your fund documents, we provide a structured quote quickly, distinguishing accounting, NAV input preparation, register keeping and reporting.
Is Financial Services Luxembourg an expert-comptable?
Financial Services Luxembourg is a licensed accountant (authorisation 10077274), subject to AED supervision for AML/CFT purposes. The "expert-comptable" title is a regulated title held by members of the Ordre des Experts-Comptables; for engagements that require it, such as certification of the accounts by an approved statutory auditor, we coordinate with the duly qualified professionals while remaining your single point of contact on the administration side.
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