Luxembourg is widely recognised as a leading fund domicile and the Luxembourg Stock Exchange (the “LuxSE”) has long‑standing experience in listing investment funds, including shares and units thereof.

Listings are typically driven by investor mandates or distribution considerations. They may enhance credibility, facilitate access to professional and institutional investors, and support cross‑border distribution. However, they are generally associated with public disclosure requirements.

To address situations where fund sponsors seek both the benefits of a listing and greater confidentiality, the LuxSE has introduced the so-called “EM3S”. This professional segment of the Euro MTF market of the LuxSE is designed for sophisticated securities, including shares and units of investment funds, offered exclusively to a limited group of professional investors and not accessible to retail investors. It allows fund sponsors to obtain the market presence and institutional credibility of a Luxembourg-listed investment fund while limiting public disclosure.

Key features of the EM3S

Streamlined admission to trading

No listing particulars or other initial disclosure document are required. Admission is based on an application form and a letter of undertaking, supported by the terms and conditions of the shares and units of investment funds, without a formal approval process, which can simplify and accelerate the admission timeline;

Limiting public disclosure framework

Fund documentation is not published by the LuxSE, allowing fund sponsors to avoid public disclosure of sensitive information such as investment or structuring strategies, portfolio composition or bespoke fund terms;

Controlled access to fund information

Fund sponsors commit to making the terms and conditions of the shares and units of investment funds available to eligible investors upon request through a designated contact point displayed on the LuxSE’s website; and

Access to a recognised European trading venue

Shares and units of investment funds are admitted to trading on the LuxSE’s Euro MTF market, offering investment funds recognised market presence and institutional credibility. Listing on the LuxSE’s Euro MTF market qualifies for certain tax exemptions and it allows a certain type of investors to meet regulatory constraints applicable to them.

Do you want to know more about this topic? Read more of our New York office Snippets or reach out to one of our colleagues mentioned below.