Ch. 12INTERMEDIATE ~20 mins

Marketing & Distribution

Cross-border distribution, passports and NPPR

Fund Type	Manager Regime	EU/EEA Marketing Route	Retail Access
UCITS	ManCo under 2010 Law	Full EU passport — home regulator (CSSF) notifies host; passport to retail + professional	Yes — full retail access across all EU/EEA
Full AIFM-regime AIF	Authorized AIFM (Chapter 2 of AIFMD)	EU passport to professional investors; retail only if host country local retail regime permits	Professional only by default; retail by local opt-in
Simplified/registered AIFM AIF	Registered/simplified AIFM (below threshold)	No EU passport — NPPR in each country individually; or local retail regimes	Very limited — country-by-country basis
Non-EU AIF (AIFMD Art. 42)	Any AIFM (EU or non-EU)	NPPR in each EU country separately — no passport available	Depends entirely on national private placement rules
ELTIF	Authorized AIFM	Full EU passport to retail + professional investors (ELTIF-specific passport)	Yes — retail passport is a core ELTIF feature

CSSF Fees for Notifications

CSSF fees and charges for marketing notifications (outbound from Luxembourg, inbound to Luxembourg) are set by Grand-ducal regulation — a practical point that affects fund launch cost modelling. Fees apply per fund/compartment notified.

▸UCITS passport: home regulator (CSSF for Luxembourg UCITS) sends notification to host regulator; host has 10 working days to confirm receipt; marketing can begin immediately on confirmation
▸AIF passport (full AIFM regime): AIFM sends notification to CSSF for outbound marketing; CSSF transmits to host within 20 working days; marketing begins after transmission
▸NPPR: no EU-wide procedure — each country sets its own national private placement rules; some have strict requirements (notification, legal opinion, local requirements)
▸Non-EU/EEA marketing: each country has its own rules — no EU framework applies; private placement exemptions, 3(c)(1)/(3(c)(7) in the US, etc.