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Data collection on commercial real estate for investment fund managers

On 8 June 2021, the CSSF issued a communication on data collection on commercial real estate for investment fund managers (IFMs) [1]. The CSSF reiterates that the real estate sector plays an important role in the economy and its developments can have a material influence on the financial system. Indeed past financial crises demonstrated that unsustainable developments in real estate markets may have severe repercussions on the stability of the financial system and of the economy as a whole. Establishing a more harmonised framework for monitoring developments in the real estate sector and in particular in the commercial real estate segment is therefore crucial to ensure early identification of vulnerabilities that could lead to future financial crises [2].

The CSSF reminds that the European Systemic Risk Board (ESRB) issued a set of recommendations in 2016 on closing real estate data gaps [2], as amended in 2019 [3], further to which a set of indicators need to be collected by national authorities as part of the risk-monitoring framework for their domestic real estate sector.

The CSSF in its communication confirms that it will implement a data collection, which will take place on a bi-annual basis and will focus on the financing of the commercial real sector by investment funds. The concerned IFM who manage funds with an exposure to the real estate market will be contacted directly by the CSSF to provide data regarding such funds, provided that they meet the following cumulative conditions:

• The funds managed by the IFM are Luxembourg regulated or unregulated investment funds, excluding UCITS set up under part I of the law dated 17 December 2010;

• The Luxembourg funds have, according to their reporting, a predominant strategy defined as “Real Estate”;

• The Luxembourg funds are neither funds of real estate funds (irrespective of the country of domiciliation of the target funds) nor feeder funds investing in a master domiciled in Luxembourg;

• The Luxembourg funds have a direct or indirect exposure to the commercial real estate market, defined as follows: “Commercial real estate means any income-producing real estate, either existing or under development, including rental housing; or real estate used by the owners of the property for conducting their business, purpose or activity, either existing or under construction; that is not classified as residential real estate; and includes social housing.” [3]

Answers are expected by 30 September 2021 and for this purpose the concerned IFMs will have to use the dedicated questionnaire, which will be made available on the CSSF eDesk portal by 11 June 2021.


[2] Recommendation of the European Systemic Risk Board of 31 October 2016 on closing real estate data gaps (ESRB/2016/14):

[3] Recommendation of the European Systemic Risk Board of 21 March 2019 amending Recommendation ESRB/2016/14 on closing real estate data gaps (ESRB/2019/3):

For further information and/or advice, feel free to contact our Investment Funds & Asset Management team:

Maria CHIAPOLINO, Senior Counsel

Françoise PFEIFFER, Senior Counsel

Laetitia SERVAIS, Counsel

Aspasia POULI, Associate

This publication is for general guidance only and does not constitute definitive legal advice.

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