A RAIF is not approved in advance as a product by the CSSF, but it follows a structured annual cycle. Its authorised AIFM, depositary, administrator, governing body and approved statutory auditor each contribute to that cycle.
The annual report is the main statutory output. It depends on records built throughout the year, especially valuation, cash, investments and investor capital. The close is easier when those records already reconcile before year-end.
The six-month annual report
The consolidated RAIF Law requires an annual report for every financial year. It must be made available to investors within 6 months after the end of the period.
The report includes a balance sheet or statement of assets and liabilities, a detailed income and expenditure account, a report on the year’s activities and the information needed for investors to understand the fund’s development and results. The presentation also reflects compartments and classes where relevant.
The accounting information must be audited by a Luxembourg approved statutory auditor. The auditor’s report, including any qualification, appears in full in the annual report.
The participants in the close
The governing body of the RAIF, or the general partner for an SCSp-form vehicle, approves the report and remains responsible for the fund’s records and decisions. The other participants contribute within their mandates.
| Participant | Main contribution |
|---|---|
| Governing body or general partner | Company or partnership decisions and final approval |
| AIFM | Management oversight, risk information and valuation framework |
| Administrator | Ledger, capital accounts and draft report |
| Depositary | Cash, safekeeping, ownership and oversight evidence |
| Approved statutory auditor | Audit procedures and opinion |
The roles are connected but not interchangeable. The administrator cannot approve the AIFM’s valuation judgment. The auditor tests the report but does not prepare the underlying portfolio evidence. A question should have one identified owner and a clear path to final approval.
Valuation and portfolio records
Valuation is often the longest part of the annual close. The methodology in the offering document and the AIFM’s policy should be applied consistently to each asset. Changes in method, overrides and significant judgment need an explanation.
Private assets require current operating data and market evidence appropriate to the selected method. The valuation date, foreign-exchange rates and accounting entries should agree. A later financing or sale may provide evidence about conditions at year-end, but it is not automatically the value on that date.
The AIFM’s approved valuation should match the amount booked by the administrator and presented to the governing body. This links the annual report directly to the regulated management framework described in the AIFM guide.
Investor capital and allocations
An SCSp-form RAIF maintains commitments, capital calls, contributions, distributions and partner accounts under its limited partnership agreement. The fund total and the investor-level accounts must reconcile.
Equalisation, excuse rights, defaults, recallable distributions and carried interest can change the allocation between investors. Each treatment should follow the partnership agreement and the notices already issued. The SCSp accounting guide explains that ledger in more detail.
The annual report should also reconcile with periodic investor statements. A year-end adjustment may be valid, but the difference needs a clear bridge to the figures previously communicated.
The audit sequence
Audit planning should begin before the report is drafted. The opening balances, first-year formation entries, valuation timetable, investment confirmations, bank and depositary evidence, capital activity and related-party transactions can be prepared in advance.
Audit adjustments are reflected before the governing body approves the report. An adjustment can also change partner accounts, subscription-tax calculations, investor statements or an AIFM filing. The corrected data should move through each affected output rather than remaining only in the annual report.
Subscription tax
The standard annual RAIF subscription-tax rate is 0.01% of net assets, subject to statutory exemptions. The current official subscription-tax procedure requires a quarterly declaration and payment within the first 20 days of the following quarter.
The annual rate is applied to the relevant quarterly base through the filing procedure. Net assets and any exemption claimed should reconcile with the administrator’s records. A final audit adjustment can therefore require a review of earlier declarations.
The direct-tax path remains a separate question. A corporate-form RAIF and a partnership-form RAIF do not follow the same return analysis. An SCSp can also require a reverse-hybrid review and partner reporting.
AIFM and depositary reporting
The authorised AIFM has regulatory reporting obligations in addition to the RAIF annual report. The CSSF’s current IFM reporting page confirms that Annex IV frequency can be quarterly, semi-annual or annual depending on the applicable position.
The portfolio, leverage, liquidity and risk data used for those filings should remain consistent with the accounting and valuation records, even where the dates or templates differ.
The depositary performs the AIF cash, safekeeping, ownership-verification and oversight duties described by the CSSF depositary framework. Depositary exceptions should be resolved through the year because they can affect both the close and the audit evidence.
The recurring calendar
Quarterly valuation, investor reporting and subscription tax create checkpoints before year-end. The year-end close then finalises the ledger, portfolio values and capital accounts. Audit and governing-body approval follow in time for the report to reach investors within 6 months.
The calendar may also include more frequent AIFM reporting and investor-specific obligations. Those additional dates do not extend the statutory six-month period.
Conclusion
The RAIF annual report is the final output of a connected operating cycle. Valuation, investor capital, subscription tax, AIFM reporting and depositary evidence should reconcile before the report is approved and audited. The six-month deadline is easier to meet when each participant owns a defined part of that cycle.
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Frequently Asked Questions
Does every Luxembourg RAIF require an annual audit?
Yes. The accounting information in the annual report must be audited by a Luxembourg approved statutory auditor.
When must the RAIF annual report be available?
The annual report must be made available to investors within 6 months after the end of the financial year.
What is the standard RAIF subscription tax?
The standard annual rate is 0.01% of net assets, subject to statutory exemptions. It is declared and paid quarterly within the first 20 days of the following quarter.
Who is responsible for the annual close?
The governing body retains responsibility for the report. The administrator prepares the books, the AIFM oversees regulated management and valuation, the depositary performs its controls and the auditor gives the audit opinion.
