Technology and Innovation Community

A significant and constructive regulatory development has taken place within the European fund landscape.

The Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg has clarified that UCITS funds, including multi-asset strategies, may gain indirect exposure to crypto-assets via regulated ETPs, subject to eligibility criteria.

Scope of Exposure

This enables access to the infrastructure underpinning:

• Stablecoins
• Tokenisation
• Decentralised finance (DeFi)
• Smart contract platforms
• Bitcoin

All the above operate on public blockchain networks, where transaction fees accrue to the underlying protocols.

Key Clarification

UCITS may invest indirectly in crypto-assets for up to 10% of NAV via eligible instruments.

Why This Is Positive for Allocators

This clarification represents a meaningful step forward for European portfolio construction. For the first time, allocators can access core digital asset infrastructure within the UCITS framework, one of Europe's most conservative, regulated, and globally distributed fund structures.

Importantly, this provides a compliant and risk-controlled pathway to incorporate digital assets into diversified portfolios, supporting broader discussions around diversification, innovation exposure, and long-term structural growth themes; all within established regulatory parameters.

While formal harmonisation across other jurisdictions (including Ireland/CBI and potential broader alignment under ESMA) is still evolving, early indications suggest increasing regulatory convergence across Europe.

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Harriet Thompson
Sales Associate
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Thanks Harriet. Interesting developments. I'm curious how the 10% cap will be implemented. Presumably, there needs to be some link between the risk profile of the underlying securities and the permitted cap in order to mitigate potential iliquidity events e.g. Woodford case. In other words, a straightforward, vanilla exposure to crypto is not the same as holding more complex or exotic crypto-related instruments, such as tokenized assets or other structured products.

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Carlos Salas
Portfolio Manager & Freelance Investment Research Consultant
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Original Message:
Sent: 02-03-2026 15:25
From: Harriet Thompson
Subject: The Evolution of UCITS Portfolio Construction: Integrating Digital Assets

A significant and constructive regulatory development has taken place within the European fund landscape.

The Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg has clarified that UCITS funds, including multi-asset strategies, may gain indirect exposure to crypto-assets via regulated ETPs, subject to eligibility criteria.

Scope of Exposure

This enables access to the infrastructure underpinning:

• Stablecoins
• Tokenisation
• Decentralised finance (DeFi)
• Smart contract platforms
• Bitcoin

All the above operate on public blockchain networks, where transaction fees accrue to the underlying protocols.

Key Clarification

UCITS may invest indirectly in crypto-assets for up to 10% of NAV via eligible instruments.

Why This Is Positive for Allocators

This clarification represents a meaningful step forward for European portfolio construction. For the first time, allocators can access core digital asset infrastructure within the UCITS framework, one of Europe's most conservative, regulated, and globally distributed fund structures.

Importantly, this provides a compliant and risk-controlled pathway to incorporate digital assets into diversified portfolios, supporting broader discussions around diversification, innovation exposure, and long-term structural growth themes; all within established regulatory parameters.

While formal harmonisation across other jurisdictions (including Ireland/CBI and potential broader alignment under ESMA) is still evolving, early indications suggest increasing regulatory convergence across Europe.

------------------------------
Harriet Thompson
Sales Associate
------------------------------