The RAIF is often described through what it avoids: prior product approval by the CSSF. Its annual operating model is better understood through what it requires. An authorised AIFM, a depositary, an approved statutory auditor and an annual report form a connected control chain under the RAIF law.¹

The calendar should be designed before the first year-end. A late valuation, incomplete portfolio file or unresolved depositary exception affects the administrator and the auditor at the same time. The RAIF formation guide sets out the legal architecture; the annual close is where that architecture is tested.

The annual-report requirement

The RAIF prepares an annual report for each financial year and makes it available within six months after year-end. The accounting information in that report is audited by a Luxembourg réviseur d’entreprises agréé.¹

The report is not just a trial balance in a longer document. It contains the financial statements, notes and information required by the RAIF framework and the fund’s constitutional and offering documents. The presentation must reflect compartments and investor classes where relevant.

The report should also reconcile with investor reporting already issued during the year. A year-end allocation that differs from quarterly capital statements needs a documented bridge.

The roles in the closing chain

The administrator maintains the books, capital accounts and reporting package. The AIFM oversees portfolio and risk management and plays a central role in the valuation framework. The depositary monitors cash flows, ownership and the controls assigned to it. The governing body of the RAIF or its GP approves the accounts and remains responsible for the report.

The auditor evaluates the financial statements and the evidence produced by that chain. It does not replace any of the four operating roles. A close is delayed when a question is passed between providers without a defined owner.

The engagement calendar should identify deliverables from each participant:

Participant	Main year-end contribution
GP or board	approvals, governance records and going-concern assessment
AIFM	valuation oversight, risk and portfolio information
Administrator	ledger, NAV, capital accounts and draft annual report
Depositary	cash, ownership and oversight confirmations
Auditor	audit procedures and opinion

Valuation and portfolio evidence

Valuation is usually the critical path. The methodology in the offering documents and AIFM policy must be applied consistently, with overrides and judgment documented. Private assets require transaction evidence, operating performance and market inputs that support the selected value.

The valuation date and foreign-exchange rates must align with the accounts. Subsequent events are reviewed separately. A financing round or exit signed after year-end can provide evidence about conditions at the reporting date, but it is not automatically the year-end value.

The AIFM’s valuation committee, the administrator’s booking and the board approval should use the same final data set. This is one reason the AIFM regime cannot be separated from the accounting timetable.

Capital accounts and the waterfall

The legal form underneath the RAIF determines how investor interests are recorded. An SCSp-form RAIF relies heavily on partner capital accounts, commitments, calls, distributions and allocations under the LPA. The SCSp accounting guide covers that ledger in detail.

The annual report must reconcile the partner-level information with the fund totals. Equalisation, carried interest, recallable distributions and default remedies should be supported by notices and the relevant LPA clauses.

The waterfall may be tested at year-end even when no carry is payable. The calculation supports disclosures, accruals and the consistency of investor statements.

Audit planning

The auditor should be appointed early enough to review the structure, materiality and timetable before year-end. New funds benefit from an opening-balance and first-close walkthrough, particularly where formation costs, equalisation or multiple compartments are involved.

The prepared-by-client list normally includes bank and depositary confirmations, investment evidence, valuation memoranda, legal documents, capital activity, expense allocations and related-party agreements. A shared data room with named owners prevents repetitive requests.

Audit differences must be resolved before the governing body approves the report. A late adjustment can affect capital accounts, investor notices and the AIFM’s reporting.

Subscription tax and direct-tax work

The standard RAIF subscription tax is 0.01% of net assets, calculated and paid quarterly, subject to statutory exemptions.¹ The net asset base and exemptions should reconcile with the administrator’s records.

The legal form also determines direct-tax filings. A corporate RAIF and a partnership-form RAIF do not use the same tax path. Reverse-hybrid and partner-reporting questions can arise for an SCSp, while corporate compartments require their own analysis.

Tax work should therefore be included in the close even when the RAIF itself benefits from a product-level exemption. Product taxation and investor or partnership reporting are separate questions.

AIFMD and investor reporting

The authorised AIFM carries Annex IV and other AIFMD reporting duties. Portfolio, leverage, liquidity and risk information must be consistent with the annual report, even when the reporting dates or templates differ.

Side letters may add investor-specific statements or deadlines. Those obligations should be mapped at launch and linked to the administrator’s data model. A bespoke disclosure assembled manually after year-end is difficult to control across several investors.

A practical close timetable

The year-end plan should start before the closing date with valuation data requests and confirmation lists. The first weeks after year-end focus on cash, portfolio and capital reconciliations. Valuations and tax positions then feed the draft report, followed by audit, governing-body approval and delivery within the six-month window.

The RAIF’s lack of product approval does not reduce this workload. It shifts responsibility toward the participants appointed to operate the fund. A clear timetable is what makes that delegated model reliable.

Footnotes

1. Law of 23 July 2016 on reserved alternative investment funds, as amended, including the authorised AIFM, depositary, annual report, audit and subscription-tax framework. ↩ ↩² ↩³