When the ordinary exit routes narrow, private equity does not stop selling — it changes counterparty. GP-led secondaries reached record volumes in 2025, and single-asset continuation vehicles now account for more than half of all continuation vehicle volume. In the September 2026 edition of AGEFI Luxembourg, our Co-Founders & Managing Partners Virginie Leroy and Lissie Goldbach set out what this means for sponsors, AIFMs and investors using Luxembourg structures.

The article covers:

• Why the regulator is looking — the CSSF's 2026 supervisory priorities include on-site controls of the valuation organisation of investment fund managers and thematic reviews of open-ended private assets funds, expressly including continuation funds. Supervision reaches the transaction through the AIFM.
• The vehicle next to the legacy fund — the SCSp and SCS as workhorses, deployed as unregulated AIFs or as RAIFs, and Bill 8814, which would allow ring-fenced compartments for SCS/SCSp AIFs.
• The same manager on both sides — the AIFMD conflicts framework, the new AIFMD II requirement for third-party AIFMs, and the evidence supervisors expect: a conflict minuted early, a clear decision trail, information parity and a genuinely involved LPAC.
• Valuation: who signs, and on what basis — why a fairness opinion is not a defence in itself, and how the CSSF's June 2026 feedback report on the valuation of less liquid and illiquid assets raises the standard of proof.
• Consent: the election is the deal — the LPAC's role, the ILPA continuation fund disclosure template and the importance of a genuine status quo option for rolling investors.
• Won in the drafting — why the decisive questions are answered years earlier, in the legacy fund's partnership agreement.

The key message: Luxembourg's framework already contains everything a defensible continuation fund needs — the vehicles, the conflicts machinery and the valuation discipline. What the regulator's attention changes is the standard of proof. A continuation fund that survives scrutiny is drafted, minuted and valued long before anyone calls it a transaction.

To discuss a GP-led transaction or the continuation fund provisions in your fund documents, please reach out to our Partners.