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BCL S 2.20 Quarterly Financial Information

Last Updated on June 10, 2025 by Arnaud Collignon

Overview

This document provides a detailed briefing on the “S 2.20 Quarterly Financial Information” report, an essential regulatory filing for alternative investment funds not authorized by the CSSF (NAF). The report, updated on March 24, 2025, outlines the requirements for NAFs to submit quarterly financial data to the BCL (Banque Centrale du Luxembourg).

✔️ Too Long ;Didn’t Read Summary

  • Who: Non-CSSF‑authorised AIFs (NAFs)
  • What: Quarterly XML report (S‑2.20), equivalent to CSSF U‑1.1
  • Structure: Multi-section XML covering fund and class-level NAV
  • When: Quarterly basis + 20 working days. First reporting 30 January 2026 for December 2025
  • How: Filing through the official secure communication channel
  • Solution: https://fund-xp.lu/excel-to-bcl-reporting/

Key Themes and Important Facts

The S 2.20 report focuses on comprehensive financial reporting for NAFs, covering general information about the sender and the NAF, detailed financial data at the NAF and unit/share class levels, and specific information on investment income and expenses.

1. Reporting Obligation and Scope

  • Mandatory for NAFs: Report S 2.20 “must be provided by alternative investment funds non-authorised by the CSSF (NAF).”
  • Exemptions: Investment funds directly supervised and authorized by the CSSF are exempt.
  • Derogation Threshold: The BCL “may grant alternative investment funds non-authorised by the CSSF a derogation from their monthly and quarterly reporting obligations if the total assets of alternative investment funds non-authorised by the CSSF remain below a fixed threshold,” currently set at “EUR 300 million.” For multi-compartment funds, the total assets of all compartments are considered.
  • Frequency and Deadline: The report must be submitted “on a quarterly basis at the latest 20 working days following the end of the period to which it relates.”

2. File type and transmission

  • XML-based: Reports must be submitted in XML format, aligned with BCL’s technical schema.
  • Submission portals: Delivered via Luxembourg’s secure platforms—eFile and/or SOFIE.
  • File naming & format rules: As defined by BCL technical documentation (e.g. naming conventions, XML instance structure).

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3. General Information on the Report and Sender (Section 2)

  • Reference Quarter: Reported in “YYYY-MM-DD” format, representing the last day of the quarter (e.g., “2025-12-31” for December 2025). This field is mandatory.
  • Reporting Status: Reports can only have two statuses: “final report” or “provisional report.” A “provisional report” is only accepted “in the reference quarter in which the first subscription was received.” Any other submission must be a “final report.”
  • Sender Identification: Includes items for “Institution type of the sender” (e.g., NAF, bank, management company) and “Institution code of the sender,” which is an identifier attributed by the BCL or CSSF.
  • Contact Information: “Name of the employee and phone number” and “Email address” of the person responsible for transmission and BCL queries are required.

4. General Information on the NAF (Section 3)

This section details identification and operational data for the NAF.

  • NAF Identification:
  • CSSF Code of the NAF (Item 2010): Mandatory if attributed for AIFMD reporting (circular CSSF 23/844), using format “FMMMMMMMM_CCCCCCCC” (V + NAF ID + underscore + sub-fund ID, or “00000000” if not an umbrella NAF).
  • BCL Institution Type of the NAF (Item 2011): Mandatory, identifies the NAF as “42” (Number allocated by the BCL to investment funds non-authorised by the CSSF).
  • BCL Code of the NAF (Item 2012): Mandatory, attributed by the BCL using format “MMMMMMMMMCCCCC” based on Luxembourg trade and company register (RCS) numbers.
  • Name of the NAF (Item 2020): Mandatory, includes entity name and sub-fund name if applicable (e.g., “ABC – A” for an umbrella NAF sub-fund, “DEF” for a non-umbrella NAF).
  • Financial Basis:
  • Base currency of the NAF (Item 2030): Mandatory, reported using ISO 4217 codes.
  • Legal Entity Identifier (LEI) (Item 2040): Mandatory if allocated, required for each specific sub-fund in umbrella funds.
  • Operational Details:
  • Valuation date (Item 2050): Mandatory, the date closest to the last day of the reference quarter for which NAV is calculated. Examples are provided for weekly, monthly, and quarterly NAV calculations.
  • Net asset value calculation frequency (Item 2060): Mandatory, with numerous options (e.g., Daily, Weekly, Monthly, Quarterly, Annually, and combinations with month/quarter-end or subscription/redemption events).
  • Launch date (Item 2070): Mandatory, the date the NAF receives its first subscription(s).
  • Closing date (Item 2080): Mandatory if the fund closed during the quarter, representing the date of the last S 2.20 report.
  • Reason for closing (Item 2090): Mandatory if closed, options include “Put into liquidation,” “Merger into another NAF,” “NAF status abandoned,” “Temporarily closed,” or “Definitively closed.”
  • Redemption frequency (Item 2100): Mandatory, with options like Daily, Weekly, Monthly, Quarterly, Biannual, Yearly, Only at maturity, or Other/Irregular.
  • Open / closed-end (Item 2110): Mandatory, classifying the NAF based on unit/share repurchase/redemption criteria. Closed-end funds include those with a fixed number of shares or redemption rights exercisable after at least 5 years.

5. Financial Information of the NAF (Section 4)

This section focuses on high-level financial movements of the NAF in its base currency.

  • Total Net Asset Value (NAV):
  • Previous Reference Quarter (Item 3010): Mandatory, must match the “Total net asset value of the reference quarter” from the prior report. For first-time filers, “0” if first subscription was in the current quarter, or previous NAV if reporting threshold was met in the current quarter.
  • Reference Quarter (Item 3020): Mandatory, the total NAV of the NAF at the valuation date.
  • Capital Flows:
  • Proceeds from all units/shares issued (Item 3030): Mandatory, net proceeds (after fees/costs) from all issued units/shares, including subscriptions in kind and shares issued in mergers.
  • Payments made for all units/shares redeemed (Item 3040): Mandatory, payments for redemptions of all units/shares, including redemptions in kind.
  • Distributions:
  • Total distributions made (Item 3050): Mandatory, total distributions (including interim dividends) for all unit/share classes with distribution rights, whose ex-dividend date falls within the quarter. Notably, distributions in bonus units/shares “must be reflected” in proceeds from units/shares issued.

6. General Information on the Unit/Share Class (Section 5)

This section requires separate reporting for each unit/share class.

  • Class Identification:
  • Code (Item 4010): Mandatory, sequential four-digit number, or CSSF code if attributed for AIFMD reporting. “0000” if no CSSF code.
  • Name (Item 4020): Mandatory, as per offering document.
  • Base currency (Item 4030): Mandatory.
  • ISIN code (Item 4040): Mandatory if assigned, otherwise optional.
  • Class Lifecycle:
  • Launch date (Item 4050): Mandatory, date of first subscription for the class.
  • Closing date (Item 4060): Optional, date last investor exits.
  • Reason for closing (Item 4070): Optional, options include liquidation, merger, abandonment of NAF status, or temporary closure.
  • Specific Instruments and Investor Base:
  • Specific instruments – FX (Item 4080): Mandatory, “true/false” indication of FX-related financial instruments (e.g., currency forwards) at the class level, regardless of hedging or investment purpose.
  • Specific instruments – Interest Rate (Item 4090): Mandatory, “true/false” for interest rate-related financial instruments (e.g., bond futures).
  • Specific instruments – Other (Item 4100): Mandatory, “true/false” for other specific financial instruments (e.g., equity index futures).
  • Investor base (Item 4110): Mandatory, “professional investor,” “well-informed investor,” “retail investor,” or “mixed,” based on the predominant type (>50%) of shareholders by value.

7. Financial Information on the Unit/Share Class (Section 6)

This section provides detailed financial data per unit/share class.

  • Units/Shares Outstanding (Item 5010): Mandatory, number of units/shares in circulation at quarter-end or valuation date.
  • Net Asset Value (NAV) per unit/share:
  • In NAF’s base currency (Item 5020): Mandatory, NAV per unit/share at the valuation date, converted to the NAF’s base currency.
  • In unit/share class’s base currency (Item 5030): Mandatory, NAV per unit/share at the valuation date, in the class’s base currency.
  • Net Return (Item 5040): Mandatory, quarterly performance (in percentage) of the unit/share class, assuming reinvestment of distributable income. Not to be annualized.
  • Capital Flows (Class Level):
  • Proceeds from units/shares issued (Item 5050): Mandatory, net proceeds for the specific class, including subscriptions in kind and merger-related issuances.
  • Payments made for units/shares redeemed (Item 5060): Mandatory, payments for redemptions for the specific class, including redemptions in kind.
  • Distributions (Class Level):
  • Total distributions made (Item 5070): Mandatory, total distributions (including interim dividends) in the NAF’s base currency for the class, where ex-dividend date falls in the quarter. Again, bonus unit distributions must be reflected as proceeds.
  • Amount of distributions made per unit/share (Item 5080): Mandatory, distributions per unit/share in the NAF’s base currency.
  • Amount of distributions made per unit/share (Item 5090): Mandatory, distributions per unit/share in the unit/share class’s base currency.
  • Income and Expenses (Class Level):
  • Income (Item 5100): Refers to income allocated to the unit/share class.
  • Expenses (Item 5110): Refers to expenses allocated to the unit/share class.

8. Investment Income and Expenses (Section 7)

This section details investment income and expenses for the reference quarter in the NAF’s base currency, reported net of taxes and not cumulative.

  • Income Categories:
  • Dividends on shares (Item 6010): Total dividends on non-NAF shares, with a sub-item for “of which from Luxembourg” (Item 6011).
  • Dividends on NAF units/shares (Item 6020): Total dividends on NAF units/shares, with a sub-item for “of which from Luxembourg” (Item 6021).
  • Interest on bonds and other debt securities (Item 6030): Total interest income, including money market instruments, with a sub-item for “of which from Luxembourg” (Item 6031).
  • Interest on loans, bank and other interest-bearing accounts (Item 6040): Total interest income from loans, term deposits, and other accounts, comprising “Bank interest” (Item 6041, with “of which from Luxembourg” as Item 6042) and “Other interests” (Item 6043, with “of which from Luxembourg” as Item 6044).
  • Other income (Item 6050): All other income, including “Rental income” (Item 6051), “Commission income” (Item 6052), and “other” (Item 6053).
  • Expense Categories:
  • Charges (Item 6060): Includes advisory/management fees (Item 6061), depository bank fees (Item 6062), NAF administration fees (Item 6063), and audit/inspection fees (Item 6064).
  • Other expenses (Item 6080): Includes “Interest paid” (Item 6081), “Personnel expenses” (Item 6082), “Rental expenses” (Item 6083), “Amortisation” (Item 6084), and “Other” (Item 6085).
  • Profits/Losses:
  • Net realised profit or loss on investments and foreign exchange positions (Item 6090): Net gains/losses realized during the quarter.
  • Net unrealised profit or loss on investments and foreign exchange positions (Item 6100): Net unrealized gains/losses.

Conclusion

The S 2.20 report is a crucial regulatory document for NAFs in Luxembourg, ensuring comprehensive quarterly financial transparency to the BCL. It mandates detailed reporting from the overall fund level down to individual unit/share classes, covering financial performance, capital flows, distributions, and granular breakdowns of income and expenses. Adherence to reporting deadlines and data accuracy is paramount, with specific examples and mandatory fields emphasized throughout the instructions.

EXTERNAL LINKS

BCL Main page : https://www.bcl.lu/en/Regulatory-reporting/Fonds_Investissement/Instructions/S0220/index.html

BCL instructions : https://www.bcl.lu/en/Regulatory-reporting/Fonds_Investissement/Instructions/S0220/S0220_L0_instructions_2025_EN.pdf