Consumer Credit Regulations in Luxembourg

The CSSF Technical FAQ on Regulation No 20-08 provides implementation guidance on **loan-to-value (LTV) limits for residential real estate credit in Luxembourg**, establishing borrower-based macroprudential measures designed to limit leverage in the mortgage market. This guidance is critical for lenders operating in Luxembourg as it clarifies how to calculate own funds, determine LTV compliance, and apply temporary portfolio exemptions that have been extended through June 30, 2025.

What Changed

The most recent update (March 9, 2026) to the Technical FAQ reflects the regulatory framework established by CSSF Regulation No 20-08 (as modified by Regulation No 24-10).
First-time buyers: LTV limit of up to 100%
Other buyers: LTV limit of 90%, implemented via portfolio allowance Buy-to-Let Residential Loans:
Standard LTV limit of 80%
Temporary exemption (until June 30, 2025): Lenders may apply LTV ratios up to 95% for up to 10% of annual production Other Residential Real Estate Loans:

Suggested Considerations

*For all lenders:
*Verify LTV compliance calculations for all new residential mortgage originations using the framework specified in the FAQ, ensuring own funds are calculated as actual equity contributions from borrowers
*Implement dual LTV tracking for borrowers financing new property through sale of existing property, ensuring compliance with both interim and final LTV ratios
*Document own funds sources carefully, particularly when cash collateral or sale proceeds are used, as these are only permitted for loans with initial LTV below 100%
*Prepare for June 30, 2025 transition by: