The CSSF also accepts that a single fund may offer both traditional and tokenised units. In that case, the register agent function may be entrusted to several entities: one for the traditional units, another for the tokenised units. Responsibilities must be clearly allocated among the identified service providers, and the fund must maintain a consolidated view of all units issued.
For dematerialised units, Luxembourg legislation introduced the control agent function in the Blockchain IV law (2024), responsible for the issuance account and the integrity of entries on the DLT. However, the CSSF reminds that appointing a control agent does not exempt the fund from appointing a register agent. The latter maintains the investor register and handles subscription and redemption orders, settlements and client communication. A single player may perform both functions if it holds the required authorisations.
Finally, these players must comply with DORA and demonstrate that they have appropriate information, control and security systems. The CSSF also considers it highly likely that the control agent activity constitutes a critical or important function.
These clarifications provide a more readable framework. They allow funds to begin a gradual transition towards blockchain, for example by tokenising a unit class or a sub-fund without immediately transferring their entire administration.