On 5 October the CSSF published its first feedback report on Circular CSSF 24/856, Luxembourg’s rules on errors at fund level. The figures on fees are the most striking, with 416 notifications of non-compliant fee payments in 2025, 326 of them overpayments, and 54 cases that lasted more than two years.
The CSSF links many of them to gaps at management companies and administrators: weak checks before and after payment, overly manual processes and poor oversight of delegates. It wants an appropriate control framework around fee payments, and while those are the immediate causes, I would think much of it comes back to a problem this market has had for 15 years.
How did the the fund data market end up with so many sources for one data point?
After the financial crisis, Europe set out to give investors clear, comparable information and to give regulators a better view of risk. The law prescribed what investors see, down to the KID template, and in AIFMD a fixed format for reporting to regulators. For the data fund managers pass to the banks and platforms selling their funds, it set out what must be shared but not how. The industry agreed those formats itself, through FinDatEx templates such as the EMT and standards such as openfunds, and that is still the model today.
As a result, the same data point can come from multiple different providers, and the bank or platform receiving it must decide which to use. In my experience, fund managers try to solve this by naming one official source, usually themselves or their administrator.
Why does costs data go stale between the fund and the market?
With costs, the first question is how long a figure remains valid. The accountant recalculates it monthly, annually or at whatever frequency applies, and each new version has to reach whoever sends it to the market. When it doesn’t, the stale figure keeps feeding calculations until they no longer reconcile, because dynamic information is being treated as static.
Who is responsible for fund data when a delegate gets it wrong?
If I sell you a car and the engine fails, the responsibility is mine, whoever built the engine, and the same applies to fund data. A management company can delegate portfolio management, administration and data work, but under both UCITS and AIFMD it can’t delegate the liability. The CSSF’s comments on oversight of delegates make the same point.
Will ESAP fix the fund data problem?
I would think the EU is not entirely satisfied with this model, not least because it is not getting the data it needs. The European Single Access Point (ESAP) is part of its answer: one place for the information firms must publish, filed in machine-readable form through national collection bodies. The first documents arrived in July 2026, SFDR disclosures follow in January 2028 and fund documents, including KIDs, in January 2030. I think it’s a good initiative: a road that lets data flow from fund managers to banks, platforms and regulators from one place.
Because ESAP is built around documents, the fund manager files its own and the source is clear, but the data banks and platforms calculate with, such as EMT cost figures, still travels through templates and intermediary vendors. Until the market takes that data from one trusted source, it is the same problem, one step removed.
How do FRAME and the new UK AIFM regime approach fund data reporting?
Since Brexit, the UK has taken a different direction. The FCA’s proposals for FRAME and a new UK AIFM regime aim for fewer, more proportionate requirements and one standardised framework for reporting fund data to the FCA, with less asked of smaller funds: under FRAME, a fund under £500m would report only an essential data set. I think that strikes the right balance, although both are still at consultation stage, with implementation expected in 2028.
What would I do to stop stale cost data reaching the market?
This hasn’t been manageable in a spreadsheet for at least 10 years, and the CSSF’s comment on manual processes points the same way. Whether you build or buy, you need a database that takes data in consistently and flags a missing cost, based on how often you expect it to be calculated. If you use a provider, ask how they detect missing or out-of-date costs, and whether they already do it for firms like yours. Automate the flow, but make sure there is a control that stops it when it breaks down.
