12th edition

Luxembourg Fund Governance Survey 2024

Sustainable Finance in Luxembourg 2024
  • Survey
  • January 23, 2025
This survey continues to be a vital resource for the Asset and Wealth Management (AWM) and Alternatives industries, offering insights from boards across Luxembourg’s fund ecosystem. In 2024, the Luxembourg fund industry faced a dynamic landscape marked by geopolitical uncertainties, market volatility, and evolving regulatory requirements. As the industry adapts to these challenges, the survey highlights the critical role of governance in maintaining Luxembourg’s position as a leading fund domicile.
Our findings emphasise the importance of effective board organisation, strategic decision-making, and the increasing integration of sustainability and ESG considerations.  

For this 12th edition, 115 participants filled out the survey, providing first-hand knowledge of the inner-workings of boards at Luxembourg-based investment funds and management companies.

Key findings

A diverse range of skills and experiences among directors ensures that the board can address complex challenges. Effective boards provide companies with different perspectives and directions, drawing on their wider external experiences. This diversity helps meet regulatory requirements, maintain accountability, and offer strategic counsel. Consistent with the 2022 findings, this edition reveals that the most common areas of expertise are Fund Governance/Professional Director, Portfolio Management and Fund Administration/Operations. Notably, the report also highlights a positive trend—female representation on boards has risen from 22% to 26%. This gradual shift toward greater gender diversity enriches discussions and fosters more innovative problem-solving, further strengthening the overall effectiveness of boards.  

Board performance evaluations are critical for assessing governance effectiveness and promoting accountability. In 2024, Super ManCos and UCITS ManCos showed a 46% increase in evaluations, while AIFs experienced a 12% rise in the lack of evaluations. AIFM boards made progress, with a 9% decrease in the number of boards without evaluations. The findings emphasise the importance for AIFMs and AIFs to adopt consistent performance evaluations to improve governance. Over 60% of boards conduct evaluations annually, with ad-hoc evaluations now at just 3%. AIFMs have notably shifted to annual evaluations, while UCITS boards are increasingly opting for biennial assessments.

The 2024 survey reveals positive trends in conflict-of-interest management among UCITS and AIF boards. The percentage of UCITS boards without a conflict-of-interest policy decreased from 14% in 2022 to 7% in 2024. Additionally, more boards now maintain a conflict-of-interest register, with UCITS increasing from 86% in 2022 to 95% in 2024, and AIFs from 72% to 78%. Almost three-quarters of boards that keep a register distinguish between actual and potential conflicts. There has also been a notable improvement in the declaration of conflicts at board meetings, with disclosures rising to 100% for UCITS and Super ManCo boards and 88% for AIFMs. These trends indicate a stronger commitment to transparency and effective governance.

When applied consistently, ESG guidelines can minimise companies’ environmental impact, helping to address climate change-related risks and foster a more sustainable business environment. Leading companies see ESG issues as a critical business priority, leveraging them to manage risks, seize opportunities, and communicate their vision for the future, ultimately positioning themselves for long-term success and value creation. ESG strategy is now considered crucial for companies and funds to drive long-term success and meet stakeholder expectations.

Luxembourg Fund Governance Survey 2024

12th edition

Contact us

Andrea Montresori

Audit Partner, PwC Luxembourg

Tel: +352 49 48 48 2436

Alexandra Letecheur

Audit Director, PwC Luxembourg

Tel: +352 621 335 158

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