What is a RAIF? — Reserved Alternative Investment Fund (Luxembourg)
A RAIF is a Luxembourg fund under the Law of 23 July 2016 that is not authorised or supervised by the CSSF at product level — there is no regulator approval step before launch. The trade-off is structural: a RAIF must appoint an authorised external AIFM, which carries the full AIFMD discipline and, with it, the EU marketing passport. It is reserved for well-informed investors.
The design goal was speed with substance. Skipping product authorisation removes the approval bottleneck — a RAIF is constituted before a notary and entered on a list at the RCS (the Luxembourg trade register) within 5 working days, with realistic time-to-market around 4–10 weeks if the AIFM is in place. But the full service stack is mandatory: authorised AIFM (a RAIF cannot self-manage or use the sub-threshold exemption), Luxembourg depositary, central administration in Luxembourg, approved statutory auditor.
Investor and capital numbers mirror the SIF, as amended by the Law of 21 July 2023: well-informed investors commit at least €100,000 (unless professional/institutional or certified expert), and net assets must reach €1,250,000 within 24 months. The default tax cost is the 0.01% annual subscription tax; the risk-capital regime and qualifying ELTIF RAIFs are exempt.
The practical gotcha: never write "unregulated" in a DDQ — the regulation sits one level up, at the AIFM, and investors' counsel will test that. Note also that CSSF Circular 25/901 does not bind RAIFs by its terms, but its risk-spreading and risk-capital readings are expected to be applied by analogy.
Where this appears on FundRegTracker
- Where to domicile a private fund — RAIF-SCSp vs JPF vs Guernsey PIF vs Irish ILP
- CSSF Circular 25/901, consolidated — the read-across question
- ELTIF 2.0 vs Part II UCI — the ELTIF label can sit on a RAIF