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LuxembourgPortail de la fiscalité indirecte

AED switches AIF questionnaire file names to RCS number, YYYYMMDD

The Excel file for the FIA AML/CFT Questionnaire 2025 must now be named with the AIF’s RCS number and the transmission date as YYYYMMDD.

By Taxxa AI OyPublished 9 October 2026

Financial Sector & Markets

The file name is the news. The Administration de l'enregistrement, des domaines et de la TVA (AED) has changed the required Excel file-naming format for the FIA AML/CFT Questionnaire 2025Public: where the page previously asked for the AIF's name followed by the transmission date as DDMMYYYYPublic, it now asks for the AIF's RCS number followed by the date as YYYYMMDDPublic. The worked example changed with it, from XYZ REAL ESTATE AIF_AML-CFT_QUESTIONNAIRE_2025_01032026.xlsx to B123456_AML-CFT_QUESTIONNAIRE_2025_20260331.xlsx, with the example transmission date moving from 1 March 2026 to 31 March 2026. The French and English versions of the page were changed identically.

The change is narrow but load-bearing for anyone who scripts the submission: an automated export that still stamps the fund name and a DDMMYYYY date will produce a non-conforming file namePublic. The new pattern is RCS-number, the literal string _AML-CFT_QUESTIONNAIRE_2025_, then the transmission date compacted to year-month-day with no separatorsPublic, under the original Excel format — any other format, for example a PDF version, is not accepted.

Everything around the file name is unchanged. Submission in 2026 remains invitation-only from the AED, with data as of 31 December 2025. The questionnaire must still be transmitted by the RR of the AIF to the AED, although the RR may mandate the RC to transmit it. Each questionnaire still goes in a separate email, without any other file or enclosure attached, to aed.aif@en.etat.lu. The 31 March 2026 figure is the page's example transmission date, not a filing deadline stated on the page.

Legal basis: AED page « AML/CFT Questionnaire FIA », file-naming instructions requiring Numéro RCS du FIA_AML-CFT_QUESTIONNAIRE_2025_AAAAMMJJ and RCS number of AIF_AML-CFT_QUESTIONNAIRE_2025_YYYYMMDD, with the cooperation duty under Article 5 of the loi modifiée du 12 novembre 2004 relative à la lutte contre le blanchiment et le financement du terrorisme cited as the frame for the invitation campaign.

Rename scripted AED questionnaire exports to the RCS-number/YYYYMMDD pattern before transmitting the FIA AML/CFT Questionnaire 2025.

Sources

AML/CFT Questionnaire FIA