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At a European UCITS platform, the sub-advisor is usually chosen by the platform's investment or manager research team, approved by the management company's board, and overseen by named officers: designated persons in Ireland, conducting officers in Luxembourg. Dakota's filings data records 2,974 board and ManCo seats across 103 platforms that use outside managers.
Key Takeaways
- Selection and approval are separate. The platform's investment team recommends a sub-advisor, and the management company (ManCo) approves the delegation and remains liable for it under Article 13 of the UCITS Directive.
- Dakota records 2,974 board and ManCo seats at 103 platforms that use outside managers: 464 fund boards (median 4 directors) and 128 ManCo boards (median 7) (Dakota analysis of CBI and CSSF registers and funds' published reports, September 2026).
- Luxembourg filings name 225 conducting-officer roles. Under CSSF Circular 18/698, conducting officers must run initial, periodic and ongoing due diligence on every delegate.
- In Ireland, the Central Bank requires designated persons for 6 managerial functions, including investment management, which covers delegate oversight.
- Independent directors hold at least one in five recorded seats: 32% in Ireland and 18% in Luxembourg.
Who decides which sub-advisor a UCITS platform hires?
Three groups share the decision. The platform's investment or manager research team selects and recommends the sub-advisor. The ManCo board approves the delegation and stays legally responsible for it. Named officers, designated persons in Ireland and conducting officers in Luxembourg, then oversee the delegate. Dakota maps these roles across 103 platforms.
A few terms used throughout this series:
- UCITS is the EU framework for regulated, liquid funds.
- An umbrella fund holds many sub-funds.
- The management company (ManCo) is the regulated firm responsible for the umbrella.
- A sub-advisor, or delegated investment manager, runs a sub-fund or a sleeve of one.
- A selector platform builds its own-branded range and chooses outside managers. A host ManCo runs umbrellas that other firms promote.
- The regulators are the Central Bank of Ireland (CBI) and Luxembourg's CSSF.
The channel is explained end to end in How Fund Managers Win UCITS Sub-Advisory Mandates in Europe.
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Role
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Where it sits
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What it decides
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What it needs from a sub-advisor
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Investment or manager research team
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The promoter or platform
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Which strategy the range needs, and which manager to recommend
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Performance, strategy fit, capacity, fees
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ManCo board
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The management company
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Approves the delegation, and remains responsible for it
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Confidence the ManCo can oversee the delegate
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Designated person for investment management (Ireland)
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The ManCo
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Oversees delegates day to day
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Regular reporting, meetings, on-site access
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Conducting officers (Luxembourg)
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The ManCo
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Run initial, periodic and ongoing due diligence on delegates
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Due diligence documentation, ongoing data
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Fund board
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The umbrella fund (company-form funds only)
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Oversees the fund and receives the ManCo's reporting on delegates
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Clean reporting through the ManCo
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What does the ManCo board do?
The ManCo board approves each delegation and carries the legal responsibility for it. Article 13 of the UCITS Directive lets a ManCo delegate portfolio management, but delegation does not reduce its liability. Dakota's data covers 128 ManCo boards at platforms that use outside managers, with a median of seven directors.
In practice, the ManCo board rarely picks the manager itself. It receives a recommendation from the investment team, or from the promoter in a hosted umbrella. It then checks that the delegation meets its obligations: the delegate is qualified, the mandate is clear, and the ManCo can monitor it and act in investors' best interests. The board can also refuse or end a delegation.
The composition varies by model:
- At an own-group platform, such as a bank's or insurer's ManCo, the board typically mixes executives of the group with independent directors.
- At a host ManCo, the board oversees many promoters' umbrellas. Here the hire is usually driven by the promoter, and the host's approval is a governance step.
What are designated persons and conducting officers?
They are the named officers who oversee delegates after the board approves them. In Ireland, the Central Bank requires designated persons for six managerial functions, one of them investment management. In Luxembourg, CSSF Circular 18/698 requires at least two conducting officers, and Luxembourg filings name 225 conducting-officer roles.
Ireland: designated persons. The Central Bank of Ireland's Fund Management Companies Guidance sets six managerial functions:
- regulatory compliance
- fund risk management
- operational risk management
- investment management
- capital and financial management
- distribution
A designated person is responsible for each function. Designated persons hold pre-approval controlled functions under the CBI's fitness and probity regime. The guidance expects the designated person for investment management to hold regular meetings with delegates and to make on-site visits.
Luxembourg: conducting officers. CSSF Circular 18/698 requires every Luxembourg investment fund manager to have at least two conducting officers. Where portfolios managed exceed €1.5 billion, those two cannot serve as conducting officers of other fund managers. Delegate oversight runs on three levels: initial due diligence, periodic risk-based due diligence and ongoing monitoring.
For a fundraiser, these officers are where the oversight case is won or lost. A strong investment case gets a manager recommended. A clear reporting and control package gets it through due diligence.
What role does the fund board play?
For company-form umbrellas, such as an Irish plc or ICAV or a Luxembourg SICAV, the fund has its own board, which oversees the fund and receives the ManCo's reporting on delegates. Dakota's data covers 464 fund boards with a median of four directors. Contractual funds, such as a Luxembourg FCP, have no board of their own; the ManCo acts for them.
Fund boards are usually one step removed from manager selection. Their job is oversight: making sure the fund is run in line with its prospectus and in investors' interests, including through its delegates. They matter to a sub-advisor in two ways:
- They see the reporting. A delegate's performance and any compliance issues reach the fund board through the ManCo.
- They sign off on changes. Changes to the fund's investment manager are typically reflected in the prospectus, which the fund board approves.
Board seats are concentrated in relatively few hands. People who sit on three or more of the boards in Dakota's data hold 28.6% of all recorded seats, and one director holds 12. Many are professional independent directors who serve across several fund ranges.
What role do independent directors play?
Independent directors bring outside oversight to fund and ManCo boards. They hold at least one in five of the board and ManCo seats Dakota records: 32% in Ireland and 18% in Luxembourg. That is a lower bound, because only titles that state independence are counted. They are more common at host ManCos (24%) than own-group platforms (17%).
Independent directors do not usually choose managers, but they ask the questions that decide whether a delegation is comfortable:
- Is the mandate clear?
- Is the fee fair to investors?
- Can the ManCo see what the delegate is doing?
- What happens if the delegate underperforms or breaches a limit?
A sub-advisor that answers those questions in its reporting makes the independent directors' job easier, and its own position more secure.
How does the process differ at selector platforms and host ManCos?
At a selector platform, the platform's own investment team chooses the manager and its own ManCo approves it, so selection and oversight sit in one group. At a host ManCo, the promoter chooses and the host approves. Dakota records 1,527 seats at own-group platforms and 1,447 at host ManCos.
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Selector platform (own-group ManCo)
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Host ManCo
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Who selects the manager
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The platform's investment or manager research team
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The promoter: a private bank, wealth manager, family office or multi-manager
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Who approves the delegation
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The platform's own ManCo board
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The host ManCo's board and officers
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Who oversees the delegate
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The platform's designated persons or conducting officers
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The host's designated persons or conducting officers
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Where to start
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The investment team
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The promoter's investment team, then the host's due diligence
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Board and ManCo seats in Dakota's data
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1,527
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1,447
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The practical difference is the order of approach. At a selector platform, one organisation owns the whole decision. At a host ManCo, the promoter is the buyer and the host is the gatekeeper, and both need to be satisfied. The largest selector platforms are profiled in our Top 10 UCITS Sub-Advisory Platforms in Europe.
How should fund managers engage each role?
Engage the decision in the order it is made: win the investment team's recommendation, then pass the ManCo's due diligence, then keep the oversight officers and boards comfortable. With 2,974 board and ManCo seats across 103 platforms, the governance layer is larger than most fundraisers expect.
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Investment team first. Bring a strategy that fills a gap in the platform's range, with capacity and a fee that works inside the platform's product.
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Prepare the due diligence pack before you are asked. Luxembourg ManCos must document initial due diligence on every delegate under CSSF Circular 18/698. Irish designated persons must be able to evidence their oversight. Have your policies, controls, reporting samples and business-continuity arrangements ready.
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Design your reporting for the oversight officers. Regular, consistent data on performance, risk, liquidity and limits is what designated persons and conducting officers review.
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Respect the board's role. Fund boards and independent directors do not usually pick managers, but they can slow or stop a change they are uncomfortable with.
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Time it to the platform's review cycle. Most seats open when platforms launch or restructure funds. Our analysis of UCITS hires and fires shows when that happens.
Delegated selection works in a similar way in UK public pensions, where LGPS pools select managers and the funds' committees oversee them; see our LGPS pools guide.
Frequently Asked Questions
Who approves a UCITS sub-advisor appointment?
The management company (ManCo) approves the delegation of portfolio management and remains legally responsible for it under Article 13 of the UCITS Directive. The recommendation usually comes from the platform's investment team, or from the promoter in a hosted umbrella, and the ManCo board signs off.
What is a conducting officer in a Luxembourg ManCo?
A conducting officer is a senior person responsible for the day-to-day running of a Luxembourg investment fund manager. CSSF Circular 18/698 requires at least two. They oversee delegates through initial due diligence, periodic due diligence and ongoing monitoring. Luxembourg filings in Dakota's data name 225 conducting-officer roles.
What is a designated person in an Irish fund management company?
A designated person is the individual responsible for one of six managerial functions the Central Bank of Ireland requires of fund management companies, including investment management. The designated person for investment management oversees delegates and is expected to meet them regularly.
Is the fund board involved in choosing a sub-advisor?
Usually not directly. For company-form funds, the fund board oversees the fund and receives the ManCo's reporting on delegates, and it approves prospectus changes that follow a new appointment. Dakota's data covers 464 fund boards with a median of four directors.
Do independent directors choose sub-advisors?
No, but they influence whether a delegation goes ahead and stays in place. Independent directors hold at least one in five of the board and ManCo seats in Dakota's data. They focus on the mandate, the fee, the ManCo's ability to oversee the delegate, and what happens if things go wrong.
Who decides at a host ManCo such as Carne or Waystone?
At a host ManCo, the promoter of the umbrella (often a private bank, wealth manager or multi-manager) usually chooses the sub-advisor. The host's board and oversight officers then approve and monitor the delegation. Both need to be satisfied.
Ready to map the decision-makers?
Dakota Marketplace maps the governance layer behind every European sub-advisory platform, read from Europe's regulatory filings:
- The decision-makers: fund-board, ManCo-board and conducting-officer roles at 103 platforms, with board composition and independent directors
- The full platform list: 125 platforms and ManCos in Ireland and Luxembourg, with sub-advised assets, umbrellas and service providers
- Every external seat: 2,036 seats by sub-fund, strategy and incumbent manager
- Hire and fire history: 676 appointments and terminations from 2025 and 2026 statements, plus earlier history
- New-manager signals: 700+ manager firms appearing on European platforms that are new to Dakota
Book a Demo to see who oversees the platforms you want to work with.
Related reading: How Fund Managers Win UCITS Sub-Advisory Mandates in Europe · Ireland vs Luxembourg: Where Europe's Sub-Advisory Mandates Sit · LGPS Pools Guide 2026
