Ch. 6INTERMEDIATE ~25 mins

Management of UCIs

ManCo, AIFM requirements and delegation

IFM Type	Manages	EU Passport	Min. Capital
Chapter 15 ManCo (UCITS)	UCITS; may also manage AIFs if AIFM-authorized or below threshold	UCITS management passport	€300,000 initial; +0.02% of AUM above €250M, capped at €10M
AIFM (full authorization)	AIFs (SIF, RAIF, Part II, ELTIF, etc.)	AIFM management passport (professional investors)	€125,000 initial (external); €300,000 (internal/self-managed)
Chapter 16 ManCo	Certain non-UCITS structures; cannot be sole activity	No EU management passport	Luxembourg-specific requirements
Self-managed UCITS	Own UCITS only; cannot manage third-party funds	No management passport	€300,000; full ManCo substance required
Internally managed AIF	Own AIF only; RAIF cannot be internally managed	No management passport	€300,000 (referenced); full AIFM regime applies

RAIF Cannot Be Internally Managed

A RAIF must always have an authorized external AIFM — it cannot be self-managed. This is a hard requirement of the RAIF Law. Internally managed AIFs (full AIFM regime) can only manage their own portfolio and cannot provide services to third parties.