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Ch. 12
EU Marketing & Passport Requirements
Cross-border marketing notification procedures
| Criterion | UCITS Passport | AIFM Passport (AIF) | NPPR | Pre-Marketing |
|---|---|---|---|---|
| Applicable To | UCITS funds | EU AIFs by EU AIFMs | Non-EU funds or non-EU AIFMs | Any fund pre-launch |
| Investor Eligibility | Retail + Professional | Professional investors only | Professional investors (country-specific) | Professional investors only |
| Notification Process | CSSF notifies host NCA in 10 days | CSSF notifies host NCA in 20 days | Direct to each host NCA | Soft probe — no formal notification |
| Marketing Commencement | Immediately after notification transmitted | After 20-day notification period | Subject to host NCA review | Allowed — but no subscription documents |
| KID/KIID Translation | Required in host language | Not prescribed (professional only) | Per host NCA requirements | Not required for pre-marketing |
| Ongoing Obligations | Annual report, KIID update, facility agent | Annual report, AIFMD reporting | Per NPPR agreement | Register any interest received |
| Reverse Solicitation | Not applicable | Not applicable | Permitted but narrow definition | Must document investor initiation |
| De-notification | 30-day notice to CSSF + NCA | 36-month minimum before de-notification | Per NPPR agreement | Immediately — no formal process |
| Countries Available | All 30 EEA states | All 30 EEA states (if AIFMD compliant) | Country-by-country | All EEA states (soft probe) |
| Key Regulation | UCITS Directive Art. 93 | AIFMD Art. 32 | AIFMD Art. 36/42 | CBDF Regulation 2019/1156 |
📌 Data sourced from Lux Investment Funds 2025, Chapters 12. Verify current requirements with CSSF at cssf.lu.