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Event Recap: NAV Oversight Under CSSF Circular 24/856

Published on 24th of June 2025

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Margaux Marchesani

As regulatory clarity continues to evolve across Luxembourg’s fund ecosystem, one thing is certain: the conversation around NAV Oversight is no longer theoretical. It is now operational, continuous, and increasingly shaped by technology.

On 3 June 2025, we welcomed a room full of fund professionals to discuss exactly that. The event brought together operational leaders, compliance experts, and technology partners to assess how CSSF Circular 24/856 is being applied in practice six months after its entry into force.

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A Timely Check-In on Oversight Readiness

Moderated by Margaux Marchesani from Next Gate Tech, the session opened by revisiting the regulatory journey. The panel featured perspectives from Paul Carr (Conducting Officer - Capital International Management Company), Pierre Bosio (Chief Operating Officer - Amundi Luxembourg), and Frédéric Botteman (Assurance Partner - PwC Luxembourg), offering insights on how the Circular’s requirements are reshaping operational frameworks, oversight responsibilities, and governance practices.

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From clarifications around NAV error thresholds to the evolving role of the réviseur d’entreprises, the regulatory expectations are now far more granular. Importantly, the discussion emphasised how many of these obligations such as ongoing monitoring or reimbursement tracking cannot realistically be met without the support of technology.

Technology, Not Just as an Enabler But a Requirement

The second half of the discussion shifted to the role of technology. Speakers shared practical insights into how their organisations are implementing dedicated systems for NAV Oversight. The message was clear: relying on manual processes or the fund administrator is no longer viable. With increasing complexity, scale, and regulatory scrutiny, robust technological frameworks are now essential.

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Examples included the use of Next Gate Tech’s platform for ex-post NAV validation through NAV Oversight and Reconciliation analytics designed to spot anomalies in an exception-based approach. The speakers noted how technology was not only improving anomalies detection but also helping structure Management Companies internal governance and enhance communication with fund boards.

Governance and Board Expectations

The Circular’s requirements around governance generated particular interest. Beyond the operational controls, panellists highlighted how their internal policies, reporting cycles, and board-level communication have evolved. There is a growing emphasis on demonstrating that oversight frameworks are not only adequate in design but also effective in practice. That includes tracking metrics, filtering noise, and ensuring that alerts are actionable.

Missed the Event? We Have You Covered

The event was filled with valuable takeaways on how the Luxembourg fund industry is adjusting its oversight posture and where the challenges still lie. To capture the full discussion, we have prepared a detailed event summary that highlights the key themes, speaker contributions, and practical insights shared during the panel.

👉 Download the full event summary here

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If your operations are affected by the new Circular — and chances are, they are — we're ready to help.