A structured drafting framework for assembling a Luxembourg AIFM authorisation file ready for CSSF first read. Built by Ikhor and shared openly.
A Claude Skill (and standalone prompt) that takes a clean LPA (or set of LPAs) and an organisation chart, and produces:
- A Programme of Activity structured for CSSF submission
- A substance and governance pack with FTE allocation by function and a fit and proper preliminary screen
- A delegation oversight register aligned with AIFMD II Article 20
- First version outlines of the risk, liquidity, valuation, conflicts, remuneration, AML, outsourcing, and business continuity policies
- An anticipated CSSF first round Q&A with 8 to 12 questions and draft answers
- A file index in the order CSSF expects, with status per item
The goal is to cut the first authorisation file from 8 to 12 weeks of senior associate work to 2 weeks of senior verification on top of structured drafts.
We run AIFM authorisations regularly. The first version of the file used to take a junior associate three weeks of locate, structure, and summarise work before a senior could engage on substance. With this prompt, the locate and structure layer is automatic. Senior time goes to judgement, to CSSF tactics, and to the questions the file itself cannot answer.
We are releasing it because the bottleneck on Luxembourg AIFM authorisation in 2026 is no longer information about AIFMD II. The Directive is in force. The Luxembourg transposition is in force. The CSSF expectations are documented. The bottleneck is execution speed: assembling a coherent file that pre empts the first round questions.
The skill compiles its rule base on a specific date (see CHANGELOG.md). Regulation moves. At runtime, if web tools are available, the skill performs a currency check against ESMA, CSSF, Legilux, and the CRF, and incorporates any material update since compilation. If web tools are not available, it declares the cutoff date and recommends manual re check before submission.
If you have Claude Skills enabled in Claude.ai or Claude Code, drop this entire folder into your skills directory. The skill triggers on prompts like:
- "we are applying for AIFM authorisation"
- "draft our programme of activity"
- "build our CSSF file"
- "what does the CSSF ask for in an AIFM authorisation"
- "structure our delegation register"
Open prompt_standalone.md. Copy the entire prompt section. Paste into Claude (Opus 4.6 or Sonnet 4.6 recommended) or any modern LLM. When the model is ready, paste your LPA and organisation chart into the same chat.
Quality is highest on Claude Opus 4.6, then Claude Sonnet 4.6, then GPT-5, in our internal testing. The structured output (file index, anticipated Q&A) holds up across models. The drafting quality of the policy summaries diverges.
The full version, with senior fund formation review, CSSF tactics, and remediation drafts of the policies and the agreements, is what we run on real authorisation files. Reach us:
- LinkedIn: send a DM to https://www.linkedin.com/company/109984825/
- WhatsApp: +352 661 228 679
ikhor-cssf-authorisation-drafter/
|-- SKILL.md The skill definition for Claude Skills
|-- prompt_standalone.md The copy paste prompt
|-- README.md This file
|-- CHANGELOG.md Version and regulatory snapshot
|-- LICENSE MIT
|-- references/
| |-- preliminary_readiness_scorecard.md Section 0: traffic light scorecard across 8 areas
| |-- cssf_authorisation_requirements.md What the CSSF asks for, in order
| |-- programme_of_activity_outline.md 17 section PoA structure with briefs
| |-- substance_documentation.md FTE thresholds, EUR 1.5bn residency rule, CO profile matrix
| |-- delegation_oversight_template.md Register columns and the Article 20 narrative
| |-- letter_box_self_test.md 11 retained powers grid, quantitative substance test
| |-- capital_and_own_funds_calculator.md Article 9 in detail, worked examples, 3 year projection
| |-- policies_summary_outlines.md First version of 8 policies
| |-- lmt_edesk_procedure.md Annex V LMTs and the CSSF eDesk procedure
| |-- loan_origination_framework.md AIFMD II LO AIF: caps, retention, prohibitions
| |-- dora_interplay.md DORA 5 pillars, register, incident management
| |-- aml_cft_extended.md BWRA, KYC, KYA, MEF, sanctions, SAR, EU AML Package 2024
| |-- three_year_business_plan.md Revenue, costs, FTE scaling, sensitivity scenarios
| |-- article_10_post_authorisation_changes.md Change management framework
| |-- cssf_application_questionnaire_mapping.md Mapping to the 11 CSSF supporting forms
| |-- cssf_first_round_questions.md 12 anticipated questions with drafting guidance
| `-- regulatory_sources_to_monitor.md URLs and update types for the currency check
|-- assets/
| `-- example_anticipated_qa.md Two worked Q&A examples
`-- test/
`-- test_inputs.md Synthetic LPA and org chart for self test
Covers
- AIFMD II compliance for authorisation (Directive (EU) 2024/927, in force 16 April 2026)
- Luxembourg Law of 12 July 2013 on AIFMs, as amended by the Law of 3 March 2026
- CSSF Circular 18/698 on substance and central administration
- CSSF Circular 22/806 on outsourcing arrangements
- CSSF Circular 25/901 framework where relevant
- The CRF May 2026 indicator update for AML/CFT
- Common SCSp / ASLP / SICAV-RAIF / Part II UCI calibration
Does not cover
- Sub threshold AIFM registration (Article 3 AIFMD)
- UCITS ManCo authorisation
- Authorisation of depositaries, central administrators, or MiFID investment firms
- Cross border distribution notifications (Articles 32, 33 AIFMD)
- Tax structuring of the AIFM or the AIFs
- A complete legal opinion. This is a structured drafting tool, not a substitute for counsel.
Calibrated for AIFMs intending to manage Luxembourg domiciled AIFs. For AIFMs managing AIFs domiciled outside Luxembourg, the substance and delegation analysis remains but the depositary and reporting requirements shift. The skill flags this.
Released by Ikhor for the Luxembourg private markets community. Use freely, modify freely, share freely. Attribution appreciated, not required. No warranty: this is a structured drafting tool, not legal advice. Always run the output through senior fund formation counsel before CSSF submission.
Built by Ikhor. Calibrated against:
- AIFMD II (Directive (EU) 2024/927) and ESMA technical standards
- The Luxembourg Law of 12 July 2013 on AIFMs, as amended by the Law of 3 March 2026
- CSSF Circulars 18/698, 22/806, 25/901, and CSSF FAQs on AIFM authorisation
- The CRF May 2026 indicator handbook
- Public guidance from Loyens & Loeff, Arendt & Medernach, Elvinger Hoss, Linklaters, Clifford Chance, A&L Goodbody, Dechert, CMS, Ogier, Maples, KPMG Luxembourg, EY Luxembourg, and others
For corrections, improvements, or contributions, contact Ikhor via the channels above.