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Ch. 6
Luxembourg Management Entity Types
ManCo vs AIFM vs Self-Managed SICAV
| Criterion | UCITS ManCo | External AIFM | Self-Managed SICAV |
|---|---|---|---|
| Regulatory Framework | 2010 Law / UCITS Directive | AIFMD / 2013 Law | 2010 Law or AIFMD |
| Minimum Capital | €300,000 initial | €125,000 initial | €300,000 (UCITS) or €125,000 (AIF) |
| Additional Own Funds | 0.02% AUM >€250M (cap €10M) | 0.02% AUM >€250M (cap €10M) | Same as applicable regime |
| Eligible Funds | UCITS only | AIFs (SIF, RAIF, ELTIF) | Own fund only |
| Conducting Officers | Min. 2, Luxembourg resident | Min. 2, Luxembourg resident | Board directors act as COs |
| Delegation Permitted | Yes (PM, risk, admin) | Yes (PM, risk, admin) | Limited — must retain substance |
| Passporting | UCITS management passport | AIFM management passport | No passport (single fund only) |
| CSSF Supervision | Direct — Chapter 15 of 2010 Law | Direct — 2013 AIFM Law | Via fund authorization |
| Substance Required | High — CSSF circular 18/698 | High — CSSF circular 18/698 | Board must have substance |
| Setup Timeline | 3–4 months (CSSF auth.) | 3–4 months (CSSF auth.) | Part of fund authorization |
| Suitable For | UCITS fund managers | AIF/PE/real estate managers | Single proprietary fund |
| Typical Advantages | Full UCITS passport, retail access | AIF flexibility, multi-fund | Simpler governance, lower cost |
📌 Data sourced from Lux Investment Funds 2025, Chapters 6. Verify current requirements with CSSF at cssf.lu.