Introduction to U1.1 Reporting Obligations
This manual serves as a definitive guide for finance professionals responsible for U1.1 reporting. It outlines the technical requirements, validation checks, and lifecycle event management mandated by the Commission de Surveillance du Secteur Financier (CSSF). A fund’s reporting history is a continuous narrative told to the regulator; therefore, rigorous adherence to these standards is of strategic importance. It ensures accurate and timely compliance, minimizes the risk of regulatory penalties, and enhances the overall integrity of the financial data that underpins regulatory supervision.
Definition of U1.1 Reporting
U1.1 Reporting is a mandatory monthly financial reporting requirement for specific Luxembourg-domiciled investment entities, as stipulated by Circular CSSF 15/627. It provides the CSSF with standardized financial data on a recurring basis, forming a critical component of its supervisory framework.
Scope of Application
The U1.1 Reporting obligations apply to the following entities:
• Luxembourg domiciled undertakings for collective investment (UCIs) subject to the Law of 17 December 2010.
• Specialised investment funds (SIFs) subject to the Law of 13 February 2007.
• Investment companies in risk capital (SICARs) subject to the Law of 15 June 2004.
This manual will now detail the core operational procedures required to execute these monthly submissions correctly.
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Core Reporting Procedures and Technical Specifications
Adherence to standardized technical and procedural requirements is not merely administrative; it is a critical prerequisite for successful regulatory filing. Precision in file formatting, submission timing, and data conventions is fundamental to the automated processing and acceptance of U1.1 reports by the CSSF, thereby preventing delays and rejections.
Submission Deadlines and Channels
The submission deadline is mandatory and strictly enforced. The U1.1 report must be delivered on the tenth calendar day of the month following the reference month at the latest. For example, a report containing financial information for August must be submitted by September 10th.
Report files must be transmitted exclusively through the specific channels defined in the “Guidelines on the U1.1 reporting“. For complete details on accepted transmission channels, users should consult the CSSF website.
File Naming Conventions
Each reporting file must strictly adhere to the specific naming convention defined in the “Guidelines on the U1.1 reporting“. This convention utilizes the standardized CSSF identifiers assigned to each entity, which can be found in the “Identifiers of UCI/SIF/SICAR” document available from the CSSF.
Currency and Exchange Rate Protocols
Base Currency Rule The general rule is that all financial figures, at both the UCI and the individual share class level, must be reported in the base currency of the UCI.
Exceptions A few specific items are exceptions to this rule and must be reported in the currency of the unit/share class:
• Item 5030: Net asset value per unit/share in the base currency of the unit/share class
• Item 5040: Net return per unit/share in the base currency of the unit/share class
• Item 5090: Amount of distributions made per unit/share in the base currency of the unit/share class
Exchange Rates When a currency conversion is necessary, the following exchange rates must be applied:
• For item 5090: Use the exchange rate against the UCI’s base currency at the time of the booking entries.
• For items 5030 and 5040: Use the exchange rate against the UCI’s base currency at the valuation date.
Mid-Month Currency Change If a UCI changes its base currency during a reference month, all amounts should be reported in the currency that is in force at the valuation date (item 2050). If the UCI submits its first “reporting U1.1” file including a new base currency, the amount reported for item number 3010 (Total net asset value of the preceding reference month) must be converted into the new base currency.
These standard procedures form the foundation for monthly reporting. The following section addresses how to manage specific, event-driven reporting triggers that occur throughout a fund’s lifecycle.
Managing UCI and Share Class Lifecycle Events
A fund’s reporting history is a continuous narrative told to the regulator. Lifecycle events—from authorization to liquidation—are the critical chapters in this narrative. Mismanaging the reporting of these events creates data inconsistencies that can trigger regulatory scrutiny and complicate future audits. Precise execution of event-driven reporting is therefore essential to maintaining a compliant and coherent record.
Initiation of Reporting
Initial Trigger The reporting obligation for any UCI begins from the reference month in which it was authorized by the CSSF.
“Null Report” For the period between authorization and the official launch of the UCI, a “null report” must be submitted monthly.
First “Final Report” (UCI) The requirement to submit the very first “final report” for a UCI is triggered by one of two events:
• The NAV has been calculated for the very first time.
• The first effective subscription has been accepted and units/shares issued. In this specific case, the UCI may report an unofficial NAV where the amount in item number 3020 must be the sum of items 3030 and 3040. A “final report” must be submitted when an official NAV has been computed.
First “Final Report” (Share Class) The activation of any new unit/share class during a reference month triggers the requirement to submit a “final report” including its specific data.
Provisional Reporting for Delayed NAV
Requirement If a final, validated NAV is not available by the submission deadline, a “provisional report” containing estimated figures must still be submitted by the tenth calendar day of the month.
Follow-up As soon as the final figures become available, a “final report” with the updated, accurate figures must be submitted to replace the provisional one.
Data Content When a provisional report uses the total net asset value (item 3020) from the previous month, the following content rules apply:
| Item(s) | Required Content |
3030 and 5050 | Proceeds from all units/shares issued during the reference month and Proceeds from units/shares issued in the base currency of the UCI for each unit/share class: 0 |
3040 and 5060 | Payments made for all units/shares redeemed during the reference month and Payments made for units/shares redeemed in the base currency of the UCI for each unit/share class: 0 |
3050, 5070, 5080, 5090 | Total distributions made during the reference month, Total distributions made in the base currency of the UCI for each unit/share class, Amount of distributions made per unit/share in the base currency of the UCI and Amount of distributions made per unit/share in the base currency of the unit/share class: 0 |
5010 | Number of units/shares outstanding for each unit/share class: same as preceding month |
5020 and 5030 | Net asset value per unit/share in the base currency of the UCI for each unit/share class and Net asset value per unit/share in the base currency of the unit/share class: same as preceding month |
5040 | Net return per unit/share in the base currency of the unit/share class for each unit/share class: 0 |
6010 to 6100 | Investment income and expenses for the reference month in the base currency of the UCI: 0 |
Cessation of Reporting (Closure, Merger, Liquidation)
Last “Final Report” (UCI) The last “final report” for a UCI is triggered by a closing, liquidation, or merger. This report must contain the following specific data:
| Item Number | Item Description | Content to be Provided |
2080 | Closing date | date on which the last investor(s) exit(s) |
2090 | Reason for closing | option: 1, 2, 3, 4, or 5 |
3020 | Total Net asset value of the reference month | value of the remaining assets still in liquidation process at end of the reference month |
3030 | Proceeds from all units/shares issued during the reference month | proceeds during the reference month |
3040 | Payments made for all units/shares redeemed during the reference month | payments during the reference month |
3050 | Total distributions made during the reference month | payments during the reference month |
If the UCI is closed only temporarily, it must submit a “null report” for any subsequent reference month, as indicated by option 4 for item number 2090.
Note on Mergers: In a merger scenario, the absorbing UCI must treat the converted shares of the absorbed UCI as new subscriptions and include this amount in item number 3030.
Last “Null Report” (UCI) The final submission for a closed-down UCI is the last “null report”. This report must contain the following specific data to formally close the reporting record:
• Item 2040 (Legal Entity Identifier): LEI if available.
• Item 2050 (Valuation date): Date on which the UCI is closed definitively.
• Item 2060 (Net asset value calculation frequency): Must be populated with the relevant option (1 to 20).
• Item 2070 (Launch date): Date on which the UCI closed down.
• Item 2080 (Closing date): Date on which the UCI is closed definitively.
• Item 2090 (Reason for closing): Must be reported as option 5.
By convention, the date of definitive closure (2080) is also reported for the valuation date (2050) and the launch date (2070).
End of Share Class Reporting When a unit/share class is fully redeemed during a reference month, it must be included in the U1.1 report for one final time with the following data:
| Item Number | Item Description | Content to be Provided |
4060 | Closing date of the unit/share class | date on which the last investor(s) exit(s) |
4070 | Reason for closing of the unit/share class | option: 1, 2, 3 or 4 |
5010 | Number of units/shares outstanding | 0 |
5020 & 5030 | Net asset value per unit/share in the base currency of the UCI and Net asset value per unit/share in the base currency of the unit/share class | last NAV per share |
5040 | Net return per unit/share in the base currency of the unit/share class | performance derived from NAV per share of the preceding reference month and last NAV per share |
5050 | Proceeds from units/shares issued in the base currency of the UCI | proceeds during the reference month |
5060 | Payments made for units/shares redeemed in the base currency of the UCI | payments during the reference month |
5070, 5080, 5090 | Total distributions made in the base currency of the UCI, Amount of distributions made per unit/share in the base currency of the UCI and Amount of distributions made per unit/share in the base currency of the unit/share class | payments during the reference month |
Having covered lifecycle events, the manual will now address the specific treatment of key data points within the report.
Key Data Treatment and Special Scenarios
Beyond lifecycle events, reporting accuracy depends on the correct classification and handling of specific financial data, including subscriptions, redemptions, and complex fee structures. This section clarifies the CSSF’s expectations for these nuanced scenarios to ensure consistent and appropriate data treatment.
Reporting Subscriptions and Redemptions
The core principle is that all subscription and redemption amounts must be reported in the month in which they directly affect the total net asset value (item 3020) of the UCI.
Furthermore, contributions in kind, as well as contributions resulting from the transformation of a non-authorised entity into an authorised UCI, must be classified and reported as subscriptions under items 3030 and 5050.
Handling “All-in” Fee Structures
For funds that utilize an “all-in” fee structure, where a single compensation amount is paid from the fund’s assets to one recipient (e.g., the management company) who then pays other service providers, a specific reporting approach is recommended. The caption used in the U1.1 report should be the same as that used in the annual accounts, based on the counterparty’s status.
The recommended caption is: “6061 – Advisory and/or management commissions and/or fees”.
After correctly handling these specific data points, the critical final step is to validate the entire report for internal consistency and accuracy before submission.
Validation, Consistency Checks, and Sanctions
The final phase of the reporting process, validation, is the most critical. The validation checks are not merely a technical hurdle; they are the logical proof that the reported data is coherent. The NAV evolution formula serves as a roll-forward verification, while the share class aggregation checks ensure bottom-up integrity. A failure in these checks indicates a fundamental inconsistency in the fund’s accounting or reporting process that must be resolved prior to submission.
Consequences of Incorrect or Delayed Submission
The CSSF may impose an administrative fine of between EUR 125 and EUR 12,500 for non-compliance.¹ The obligation to submit the monthly report is considered unmet under the following conditions:
• The report is not delivered on time.
• The contents of the report are incorrect, incomplete, or do not comply with the mandated naming conventions or consistency checks.
Pre-submission Validation Rules
A UCI’s reporting obligation explicitly includes the provision of reports containing correct and complete figures that are consistent with themselves and with the XSD specifications. All official validation rules are detailed in the “Guidelines on the U1.1 reporting” document.
The following checks are crucial for submitting a valid and coherent file.
General Figures Check (NAV Evolution) This check ensures that the movement in the Total Net Assets (TNA) from one month to the next is arithmetically correct and fully explained by the reported flows and performance. The formula is as follows:²
TNA (T) = TNA (T-1) + SUBS – REDS – DIS + MV
• TNA (T): Total net asset value of the reference month (item 3020).
• TNA (T-1): Total net asset value of the preceding reference month (item 3010).
• SUBS: Proceeds from all units/shares issued during the reference month (item 3030).
• REDS: Payments made for all units/shares redeemed during the reference month (item 3040).
• DIS: Total distributions made during the reference month (item 3050).
• MV: The investment income and expenses for the reference month in the base currency of the UCI (income, expenses and market price effects), calculated as the net sum of items 6010 to 6100: +6010 +6020 +6030 +6040 +6050 -6060 -6070 -6080 +6090 +6100.
Share Class Specific Checks (Aggregation) These formulas ensure accuracy and completeness by verifying that the aggregated figures from all active share classes correctly reconcile with the overall UCI-level figures.
1. Total Net Assets (TNA) Check This check verifies that the total NAV of the UCI (item 3020) correctly aggregates the net asset values of all constituent share classes.³ TNA = Sum of (NSOi * NAVpSi) for all share classes.
• TNA: Total net asset value of the reference month (item 3020).
• NSOi: Number of units/shares outstanding for each share class (item 5010).
• NAVpSi: Net asset value per unit/share in the base currency of the UCI for each share class (item 5020).
2. Subscriptions Check This check verifies that total subscriptions for the UCI (item 3030) equal the sum of subscriptions across all share classes.⁴ SUBS = Sum of (SUBSpSi) for all share classes.
• SUBS: Proceeds from all units/shares issued during the reference month (item 3030).
• SUBSpSi: Proceeds from units/shares issued in the base currency of the UCI for each share class (item 5050).
3. Redemptions Check This check verifies that total redemptions for the UCI (item 3040) equal the sum of redemptions across all share classes.⁵ REDS = Sum of (REDSpSi) for all share classes.
• REDS: Payments made for all units/shares redeemed during the reference month (item 3040).
• REDSpSi: Payments made for units/shares redeemed in the base currency of the UCI for each share class (item 5060).
4. Distributions Check This check verifies that total distributions for the UCI (item 3050) equal the sum of distributions across all share classes.⁶ DIS = Sum of (DISpSi) for all share classes.
• DIS: Total distributions made during the reference month (item 3050).
• DISpSi: Total distributions made in the base currency of the UCI for each share class (item 5070).
These validation checks serve as the final safeguard of reporting quality and are indispensable for successful compliance.
Conclusion
This manual has detailed the essential procedures, lifecycle event protocols, and validation checks for U1.1 reporting. The key message is that rigorous, systematic adherence to these standards is non-negotiable for maintaining compliance with CSSF requirements. By integrating these practices into the reporting workflow, finance professionals can ensure accuracy, timeliness, and regulatory alignment.