Payments & E-Money in Luxembourg

Key dates

2025-01-17

DORA became applicable to financial entities within the CSSF supervisory perimeter.

2025-12-17

The European Commission confirmed through DORA Q&A DORA102-3097 that DORA applies to qualifying third-country branches in an EU country.

2026-08-27

Circular CSSF 26/915 was published and its amendments took effect immediately.

2027-02-27 Deadline

The six-month transition period for PSPs not otherwise subject to DORA under Circular CSSF 25/893 is expected to end; the DORA incident-reporting framework then applies to those PSPs and Circular CSSF 21/787 is repealed for them.

2027-03-31 Deadline

Latest date in the annual CSSF register-of-information submission window for arrangements contracted during 2026, subject to the applicable CSSF collection process.

Suggested considerations

• Firms should map each Luxembourg third-country branch against the DORA Article 2(1)(a) to (t) categories as the undertaking would be classified in the third country, documenting the legal-entity and regulatory-status analysis.
• Compliance teams may wish to update the branch's regulatory inventory, DORA applicability assessment, governance documentation and responsibility matrices to reflect immediate inclusion where the qualifying test is met.
• Affected branches should review ICT third-party-service contracts, the register of information and planned arrangements supporting critical or important functions, including whether CSSF notification was made at least three months before implementation or one month where the specified Luxembourg support-PFS exception applies.
• Firms should distinguish ICT outsourcing from other outsourcing: ICT outsourcing should be managed under the DORA framework and Circular CSSF 25/882, while non-ICT outsourcing remains subject to Circular CSSF 22/806 Part I.
• Incident-response teams should test the CSSF eDesk Portal and S3 API reporting channels and maintain a contingency process for notifying ictrisksupervision@cssf.lu by the applicable deadline if technical failure prevents use of the primary channel.
• Firms should confirm that major ICT incidents are reported individually and that outsourced reporting arrangements preserve the firm's responsibility for timing, completeness and notification content.
• Affected branches should assess whether they are microenterprises under DORA Article 3(60), since Circular CSSF 25/892 excludes microenterprises from its aggregated-cost estimation framework, except for trading venues, central counterparties, trade repositories and central securities depositories.
• Where the branch is an EU branch rather than a third-country branch, firms should verify the home-Member-State allocation rules because the CSSF circulars generally exclude EU branches from the relevant Luxembourg reporting chapters.

What changed

The circular implements the European Commission's 17 December 2025 DORA Q&A position and includes qualifying third-country branches in the scope of Circulars CSSF 25/882 on ICT third-party services, 25/892 on aggregated annual costs and losses from major ICT incidents, and 25/893 on major ICT-related incident and significant cyber-threat reporting.

Key dates

2025-01-17

DORA began applying to in-scope financial entities supervised by the CSSF.

2025-12-17

The European Commission confirmed through DORA Q&A 102 that DORA applies to qualifying third-country branches in an EU Member State.

2026-06-30 Deadline

CSSF’s extended best-efforts deadline for the first register-of-information submission by third-country branches of credit institutions headquartered in a third country.

2026-08-27

Circular CSSF 26/915 was published and took effect immediately; the listed CSSF circulars were amended to include or remove qualifying third-country branches as applicable.

2027-03-31 Deadline

Target date identified by CSSF for the required-quality register-of-information submission by third-country branches of credit institutions headquartered in a third country.

2027-01-11

Relevant CRD VI third-country-branch provisions are scheduled to take effect, subject to national transposition and applicable transitional rules.

Suggested considerations

• Firms should map each Luxembourg third-country branch against the counterfactual test in Circular 26/915: whether the head-office undertaking would qualify under Article 2(1)(a) to (t) of DORA if established in the relevant third country.
• Affected branches should update their regulatory-perimeter inventories, governance documents, ICT-risk policies, outsourcing inventories, incident-classification procedures and DORA control testing to reflect immediate inclusion in the DORA-specific CSSF circulars.
• Compliance teams may wish to separate non-ICT outsourcing, which remains subject to Part I of Circular CSSF 22/806, from ICT outsourcing, which is governed by DORA and Circular CSSF 25/882 rather than the legacy Part II framework.
• Affected entities should validate their register-of-information process under DORA and Circular CSSF 25/882, including branch-level data, ICT third-party contracts, intra-group arrangements and submission ownership. The 30 June 2026 best-efforts deadline for third-country branches of credit institutions has passed, and firms should prepare for the 31 March 2027 collection and any CSSF remediation requests.
• Incident-response teams should test access to the CSSF eDesk procedure and S3 API and document an escalation process for emailing ictrisksupervision@cssf.lu when technical impossibility prevents electronic submission.
• Firms should assess whether they qualify for the microenterprise exclusion in Circular CSSF 25/892; the exclusion applies to entities employing fewer than 10 persons with annual turnover and/or annual balance-sheet total not exceeding EUR 2 million, subject to the DORA definition and exclusions for specified market infrastructures.
• Third-country banking groups should coordinate DORA implementation with the CRD VI third-country-branch analysis, including the 11 January 2027 effective date for relevant CRD VI provisions, rather than assuming that the two regimes have identical scope or timing.

What changed

Qualifying third-country branches are added to the scope of Circulars CSSF 25/882, 25/892 and 25/893, covering DORA ICT third-party-service information and reporting, estimation of aggregated annual costs and losses from major ICT-related incidents under Article 11(11) of DORA and the Joint ESA Guidelines JC/GL/2024/34, and reporting of major ICT-related incidents and significant cyber threats.

Key dates

2025-01-17

DORA became applicable to financial entities within its scope, subject to the specific DORA provisions and technical standards applicable to each entity.

2025-04-09

Circular CSSF 25/881 was published and took effect, removing DORA financial entities from Circular 20/750 and retaining 20/750 for entities outside DORA; PSP-specific provisions were reorganised under Circular 25/880.

2026-06-30 Deadline

CSSF extended the first Register of Information submission for Luxembourg branches of third-country credit institutions to this date on a best-efforts basis; the CSSF indicated that the required level of quality should be achieved for the 2027 submission.

2026-08-27

Circular CSSF 26/915 was published, confirming the DORA treatment of qualifying third-country branches and removing them from the full scope of Circular 20/750 and related overlapping circular provisions.

2027-03-31 Deadline

Target date identified by the CSSF for the required-quality Register of Information submission by Luxembourg branches of third-country credit institutions.

Suggested considerations

• Firms should classify each Luxembourg entity and branch against DORA Article 2 and the amended scope of Circular 20/750, including an assessment of whether a third-country head office would qualify under DORA Article 2(1)(a) to (t).
• Compliance teams may wish to determine whether the entity should operate under DORA rather than 20/750, and document the rationale, legal-entity perimeter and treatment of any Luxembourg branch.
• Firms remaining within Circular 20/750 should consider reviewing their ICT and security-risk-management framework, governance approvals, risk assessments, incident processes, business-continuity arrangements and control testing against the continuing requirements.
• Payment service providers should consider replacing references to the PSP provisions formerly contained in Circular 20/750 with the applicable requirements in Circular CSSF 25/880 and EBA/GL/2025/02.
• Third-country branches treated as DORA entities should consider validating their DORA governance, ICT-risk framework, incident-reporting arrangements, ICT contractual inventory and Register of Information processes, taking account of CSSF reporting communications.
• Firms should update policies, regulatory inventories, outsourcing and ICT-third-party registers, training materials and regulatory mapping to distinguish DORA obligations from the residual Circular 20/750 obligations.
• Compliance teams may wish to retain evidence of the scope assessment and implementation date, because the 2025 amendment was effective immediately and the 2026 amendment changes the treatment of a previously identified 20/750 population.

What changed

Circular 25/881 provides that DORA financial entities supervised by the CSSF no longer fall within Circular 20/750; for entities covered by 20/750 but outside DORA, the circular continues to apply in full. Payment-service-provider-specific ICT and security-risk provisions were removed from 20/750 and regrouped in Circular CSSF 25/880, reflecting the revised EBA Guidelines on ICT and security risk management for payment service providers, including EBA/GL/2025/02.

Key dates

2025-01-17

DORA began applying to financial entities within its scope, subject to the relevant provisions and transitional arrangements.

2025-04-09

Circular CSSF 25/883 was published and applied with immediate effect, amending Circular CSSF 22/806 and introducing the DORA-based division between ICT and business-process outsourcing.

2025-12-17

The European Commission confirmed through a DORA Q&A that DORA applies to qualifying third-country branches in an EU Member State.

2026-06-30 Deadline

CSSF-extended submission date for the 2026 DORA register of information for third-country branches of credit institutions headquartered in a third country; entities were invited to submit on a best-efforts basis.

2026-08-27

Circular CSSF 26/915 was published and applied with immediate effect, confirming the DORA treatment of qualifying Luxembourg third-country branches and updating Circular CSSF 22/806 accordingly.

2027-03-31 Deadline

Target CSSF submission deadline for the DORA register of information for affected third-country branches following the initial 2026 collection.

Suggested considerations

• Firms should classify each outsourcing arrangement as ICT or non-ICT and determine whether the entity and arrangement fall within DORA, Circular 22/806, or both regimes in their respective areas of application.
• DORA entities should consider moving ICT arrangements from their Circular 22/806 outsourcing inventory and controls into the DORA ICT third-party register, while retaining Circular 22/806 controls for business-process outsourcing.
• Non-DORA entities should consider continuing to apply the full Circular 22/806 framework to ICT and business-process outsourcing, including due diligence, governance, critical-or-important assessments, monitoring, sub-outsourcing and exit planning.
• Third-country branches should assess whether their head office would qualify under Article 2(1)(a) to (t) of DORA and, if so, align ICT governance, contractual arrangements, registers and reporting with DORA rather than relying solely on Circular 22/806.
• Compliance teams may wish to review cloud contracts and avoid carrying forward legacy EEA governing-law or hosting clauses where DORA now provides the applicable framework, while preserving enforceable audit, access, cooperation, security, business-continuity and exit rights.
• Firms should use the revised CSSF notification form for new critical or important ICT outsourcing arrangements and preserve evidence supporting the three-month notification period, or the one-month period for arrangements involving a support PSF.
• Firms should consider validating that existing ICT outsourcing notifications remain complete under the applicable DORA register-of-information requirements, even though Circular 25/883 does not require their re-submission.
• Affected third-country branches should consider submitting and maintaining the DORA register of information through the CSSF process, with the 2027 collection requiring data quality suitable for the 31 March 2027 submission deadline.

What changed

From 9 April 2025, DORA entities generally no longer apply the ICT-outsourcing provisions of Circular CSSF 22/806 to ICT arrangements; those arrangements are governed by DORA, including its ICT third-party risk-management, contractual, register-of-information and oversight requirements, together with Circular CSSF 25/882. Circular 22/806 continues to apply to business-process outsourcing by DORA entities, and continues to apply in full to non-DORA entities, including their ICT outsourcing. Chapter 16 management companies remain subject to Circular 22/806 for ICT outsourcing.

Key dates

2025-05-19

The Joint ESA Guidelines JC/GL/2024/34 apply at ESA level.

2025-05-31

Circular CSSF 25/892 applies to its original in-scope Luxembourg entities, excluding DORA microenterprises.

2026-08-27

Circular CSSF 26/915 is issued and applies with immediate effect, bringing qualifying Luxembourg third-country branches into the scope of Circular CSSF 25/892.

Suggested considerations

• Compliance teams may wish to determine whether each Luxembourg entity or third-country branch falls within the amended scope, including whether a third-country head-office undertaking would qualify under DORA Article 2(1)(a) to (t).
• Firms should consider documenting their microenterprise analysis against DORA Article 3(60), including the fewer-than-10-employees and EUR 2 million annual turnover and/or balance-sheet-total thresholds, while noting that the DORA definition excludes trading venues, central counterparties, trade repositories and central securities depositories from the microenterprise exemption.
• Firms should consider maintaining an incident-level ledger linking major ICT-related incidents, DORA final-report reference codes, gross costs, losses, provisions, recoveries and subsequent adjustments.
• Finance, operational-risk and ICT-incident teams may wish to agree whether the firm will use a completed calendar year or completed accounting year as its reference basis and establish controls to apply that basis consistently.
• Firms should consider reconciling estimates to financial-statement or supervisory-reporting data where available, while retaining documented estimation methodology and assumptions where accurate data is unavailable.
• Firms should consider tracking quantifiable financial impacts from prior-year major incidents because those impacts may need to be included in a later reference year without reopening the original final incident report.
• Third-country branches may wish to confirm reporting ownership and data availability with their head office, because the amended CSSF scope is at branch level but the required cost and loss information may arise across the undertaking.
• Compliance teams may wish to monitor CSSF communications for a specific request, reporting channel and submission deadline; the circular itself establishes an upon-request obligation rather than a fixed automatic annual filing deadline.

What changed

From 2025-05-31, in-scope Luxembourg financial entities other than DORA microenterprises must be able, upon CSSF request, to provide an entity-level estimate of aggregated annual costs and losses arising from major ICT-related incidents. The estimate must use the ESA common template and identify each relevant incident by the same reference code used in its DORA final incident report.

Key dates

2025-01-17

DORA provisions became applicable to financial entities in scope and supervised by the CSSF.

2025-05-28

Circular CSSF 25/893 was published and established the Luxembourg DORA incident and significant cyber-threat reporting modalities.

2025-11-28 Deadline

End of the six-month transition period granted to payment service providers outside DORA for implementation of the Circular 25/893 framework.

2026-08-27

Circular CSSF 26/915 was published and the 25/893 page was updated to clarify DORA applicability to qualifying third-country branches in Luxembourg; the amendment applies immediately.

Suggested considerations

• Compliance teams may wish to confirm the entity-by-entity scope analysis against DORA Article 2, including whether a Luxembourg third-country branch is covered following the 27 August 2026 clarification.
• Firms should consider documenting incident-classification criteria and decision records against Commission Delegated Regulation (EU) 2024/1772, including the quantitative thresholds for clients, transactions, duration, geographical spread, data loss, economic impact and reputational impact.
• Firms should consider testing an escalation timetable that supports classification, initial notification within four hours and no later than 24 hours after awareness, the 72-hour intermediate report and the one-month final report.
• PSPs outside DORA may wish to update policies so that all ICT-related incidents, rather than only payment-service incidents, are assessed under the DORA framework and to verify that the six-month transition requirements were completed by 28 November 2025.
• Firms should consider ensuring that eDesk access, authorised users, templates, internal approvals and S3 API connectivity are operational before an incident occurs.
• Incident-response procedures may wish to prohibit aggregation of separate major incidents where the CSSF reporting process requires event-specific submissions and should assign ownership even where reporting support is outsourced.
• Third-country branches may wish to align their Luxembourg reporting playbooks, head-office escalation arrangements and local CSSF contacts with the immediate-effect scope clarification.
• Firms should consider retaining evidence of classification, notification times, report versions, management approvals and communications with ICT third parties to demonstrate timely compliance.

What changed

DORA financial entities supervised by the CSSF must classify ICT-related incidents using the criteria and thresholds in Commission Delegated Regulation (EU) 2024/1772 and report each major ICT-related incident using the DORA reporting templates and procedures. Reporting is phased: an initial notification is generally due within four hours after classification as major and in any event no later than 24 hours after the entity becomes aware of the incident; an intermediate report is generally due within 72 hours after the initial notification; and a final report is generally due within one month...

Key dates

2022-04-22

Circular CSSF 22/806 was published and replaced or amended specified earlier CSSF and IML outsourcing, governance and control circulars.

2022-06-30

Circular CSSF 22/806 became applicable according to the CSSF implementation framework.

2025-01-17

DORA Regulation (EU) 2022/2554 became applicable to in-scope financial entities, creating the primary EU framework for ICT third-party risk management.

2025-04-09

Circular CSSF 25/883 was published; the amended Circular 22/806 applies to outsourcing arrangements entered into, reviewed or amended on or after this date.

2025-12-17

The European Commission confirmed that DORA also applies to qualifying third-country branches in an EU Member State where the third-country head-office entity would fall within DORA Article 2(1)(a) to (t).

2026-08-27

Circular CSSF 26/915 was published and the CSSF webpage consolidated the amended version of Circular 22/806, confirming the DORA treatment of qualifying Luxembourg third-country branches.

Suggested considerations

• Firms should map each outsourcing and third-party technology arrangement against the applicable regime: DORA, Circular 22/806 business-process outsourcing requirements, or the full Circular 22/806 framework for non-DORA entities.
• Compliance teams may wish to review whether Luxembourg third-country branches have a head-office activity that corresponds to a DORA Article 2(1)(a) to (t) financial entity and document the resulting DORA scope assessment.
• Firms should update outsourcing policies, risk assessments, governance approvals, materiality or criticality assessments, due-diligence files, monitoring controls and exit strategies to reflect the split between DORA ICT third-party risk management and Circular 22/806 business-process outsourcing.
• Firms should maintain or update the DORA register of information for ICT third-party arrangements where DORA applies, and reconcile it with the outsourcing inventory and CSSF notification processes.
• Firms should review legacy cloud contracts and remove reliance on the repealed Circular 22/806 EEA-law and EEA-resilience clauses where DORA is the applicable ICT third-party regime, while retaining contract terms needed to satisfy DORA and any applicable national requirements.
• Non-DORA entities should consider whether their existing contracts still address Circular 22/806 requirements for access and audit rights, sub-outsourcing, confidentiality, data location, business continuity, termination and exit.
• Management companies authorised solely under Article 125-1 should consider retaining the full Circular 22/806 control framework for ICT outsourcing rather than assuming that DORA displaces it.
• Firms should assess whether outsourcing arrangements entered into, reviewed or amended from 9 April 2025 require remediation or re-papering under the amended framework.

What changed

Circular 25/883 amended Circular 22/806 following DORA Regulation (EU) 2022/2554 becoming applicable on 17 January 2025. For entities subject to DORA, the ICT-outsourcing provisions of Circular 22/806 were largely repealed or displaced by DORA's ICT third-party risk-management requirements, while Circular 22/806 remains applicable to business-process outsourcing.

Key dates

2020-08-25

Circular CSSF 20/750 was originally published, establishing CSSF expectations for ICT and security risk management.

2025-01-17

Regulation (EU) 2022/2554 on digital operational resilience for the financial sector became applicable to DORA-defined financial entities supervised by the CSSF.

2025-04-09

Circular CSSF 25/881 amended Circular 20/750, narrowing it primarily to non-DORA entities and moving PSP-specific requirements to Circular CSSF 25/880.

2026-08-27

Circular CSSF 26/915 was published and applies with immediate effect; DORA-equivalent third-country branches are removed from Circular 20/750 and addressed through the DORA-related CSSF framework.

Suggested considerations

• Firms with Luxembourg third-country branches should document an entity-by-entity DORA scoping analysis, including the classification of the non-EU head-office undertaking under Article 2(1)(a) to (t) of Regulation (EU) 2022/2554 and the relevance of Article 2(2).
• Affected branches should consider retiring Circular 20/750 as their primary ICT framework and mapping controls instead to DORA and the applicable CSSF circulars, including Circular CSSF 25/882 on ICT third-party services and Circular CSSF 25/893 on major ICT-related incidents and significant cyber threats.
• Firms should review ICT third-party inventories, contracts, due diligence files, exit strategies and, where relevant, the DORA Register of Information so that all ICT services are captured regardless of whether the arrangement is formally classified as outsourcing.
• Entities remaining within Circular 20/750 should consider confirming that the management body has approved the ICT and security risk-management framework and that it is reviewed at least annually.
• Remaining in-scope entities should consider refreshing their annual ICT and security risk assessment, critical-function and information-asset mapping, threat and vulnerability monitoring, access controls, patching, backup, recovery, incident-response and business-continuity documentation.
• Compliance teams may wish to verify that critical ICT systems undergo security testing at least annually, non-critical systems are tested regularly and at least every three years, and critical business continuity arrangements are tested at least annually.
• Branches and PSP-related entities should consider validating incident-reporting channels and escalation procedures, including the CSSF alternative email channel for exceptional technical failures where the prescribed DORA reporting channel cannot be used.
• Firms should consider preserving evidence of proportionality assessments, control testing, audit findings, remediation, management-body reporting and staff security training for CSSF supervisory review.

What changed

Circular 26/915 applies with immediate effect and removes DORA-equivalent third-country branches from the scope of Circular 20/750. A third-country branch is treated as DORA-relevant where, in the jurisdiction of its head office, the undertaking would qualify as an entity listed in Article 2(1)(a) to (t) of Regulation (EU) 2022/2554, subject to the applicable exclusions and Article 2(2) conditions.

Key dates

20 January 2026

– CSSF Circular 26/906 on central administration, internal governance and risk management for payment institutions, electronic money institutions and account information service providers is published

23 March 2026

– Decision date of the administrative sanction imposed on members of the board of directors of an electronic money institution

30 June 2026

– Application date of CSSF Circular 26/906, from which its governance and risk‑management requirements formally apply to payment institutions and electronic money institutions

21 July 2026

– CSSF publicly releases the notice “Administrative sanction of 23 March 2026 – Administrative sanction imposed on the members of the board of directors of an electronic money institution.”

Suggested considerations

• Review and map the institution’s current governance framework, board charter and committee mandates against the detailed requirements of CSSF Circular 26/906, including central administration, board composition, responsibilities and functioning.
• Ensure that the board of directors collectively has the required expertise, independence, diversity and time commitment, and that this is documented and periodically reassessed in line with CSSF expectations.
• Update board policies to explicitly assign responsibility for strategy, risk appetite, safeguarding of client funds, information security, outsourcing, conflicts of interest and AML/CFT, and ensure these responsibilities are effectively discharged and evidenced.
• Confirm that the institution’s central administration, decision‑making centre and administrative centre are physically located in Luxembourg and that members of the management body are sufficiently present on site, as required under the governance framework.
• Establish or reinforce the “three lines of defence” model by clearly separating business units, control functions (compliance and risk) and internal audit, and ensure reporting lines to the board are independent and robust.

What changed

• - The CSSF demonstrates that it is prepared to impose administrative sanctions directly on members of the board of directors of electronic money institutions, not just on the institution as a legal...
• Board members of Luxembourg‑authorised electronic money institutions are now clearly exposed to personal regulatory liability for governance, risk management and safeguarding failures under the CSSF...
• This enforcement confirms that CSSF Circular 26/906 on central administration, internal governance and risk management for payment institutions and electronic money institutions is not only a formal...
• The sanction underscores CSSF expectations that the supervisory body (board of directors) must ensure sound and prudent management, continuity of the institution and protection of its reputation, and...
• The case signals a stricter enforcement posture by the CSSF towards the payments and e‑money sector, aligning its expectations and enforcement intensity more closely with bank‑equivalent governance...

Key dates

20 January 2026

– CSSF publishes Circular 26/906 on central administration, internal governance and risk management for payment and e‑money institutions, raising supervisory expectations for the sector

2 March 2026

– CSSF issues the administrative sanction decision imposing an administrative fine of EUR 12,000 on PingPong Europe S.A. as an electronic money institution

30 June 2026

– Effective date of CSSF Circular 26/906, from which strengthened governance, risk management and safeguarding requirements apply to payment and e‑money institutions

8 July 2026

– CSSF publicly publishes the administrative sanction of 2 March 2026, formally informing the market and stakeholders

Suggested considerations

• Review the CSSF sanction against PingPong Europe S.A. and identify which categories of requirements (e.g. governance, safeguarding of client funds, reporting, outsourcing, internal controls) were implicated, then map these to your own control framework.
• Conduct a gap analysis against CSSF Circular 26/906, focusing on central administration, internal governance, risk management, and safeguarding of client funds for payment and e‑money institutions.
• Update policies, procedures and internal control documentation governing payment services, e‑money issuance, safeguarding (segregation, reconciliations), outsourcing and IT connectivity to ensure alignment with CSSF Circular 26/906.
• Ensure that a clearly designated member of the management body holds documented responsibility for oversight of safeguarding arrangements and compliance with CSSF requirements for payment and e‑money institutions.
• Implement or enhance daily reconciliations and robust segregation of client funds accounts, supported by periodic internal reviews and testing of safeguarding controls.

What changed

• (From the enforcement notice itself, there are no new rules; the impact is interpretative and enforcement‑related.)
• CSSF confirms that authorised electronic money institutions are subject to active supervisory and enforcement scrutiny, including public administrative sanctions for regulatory breaches.
• The sanction demonstrates that failures which may appear operational or procedural can nonetheless result in monetary fines and public naming, reinforcing the need for robust compliance frameworks in...
• The case is likely to be assessed by CSSF in light of the new governance, risk management and safeguarding expectations introduced under CSSF Circular 26/906 for payment and e‑money institutions,...
• The public nature of the sanction underscores CSSF’s use of transparency as a deterrent tool, increasing reputational risk for firms that do not comply with licensing, governance, reporting or...

Key dates

18 June 2025

- FATF adopts modifications to Recommendation 16 to enhance payment transparency, including strengthened travel‑rule standards

24 June 2026

- FATF launches public consultation on guidance for the implementation of the updated Recommendation 16

21 August 2026 Deadline

- FATF public consultation period closes; this is the deadline for private‑sector contributions highlighted by the CSSF

End 2030

- FATF’s revised Recommendation 16 framework is expected to be fully effective, with jurisdictions having implemented the standard into national law or regulation by this date

Suggested considerations

• Map and document all existing and planned cross‑border payment and value‑transfer flows (including virtual asset transfers) to identify where FATF Recommendation 16 and travel‑rule obligations currently apply or will apply by 2030.
• Review the June 2025 FATF modifications to Recommendation 16 and the current consultation materials, and perform a gap analysis against your existing AML/CTF, KYC and payments data standards, including thresholds, data fields, and monitoring use‑cases.
• Establish an internal project for travel‑rule implementation and enhancement that spans AML, operations, technology, legal and data‑protection teams, with explicit ownership and governance.
• Strengthen beneficiary‑side transaction‑monitoring rules to use incoming travel‑rule data for sanctions, fraud and AML detection, including controls to identify misdirected or unusual payments based on name, location, and other attributes.
• Review and, where necessary, update customer due diligence and KYC procedures to ensure the availability and verification of data fields that will be required to travel with transactions (for example, address, town and country, identification numbers, date of birth).

What changed

• *(Based on the CSSF notice plus the 2025 FATF revisions to Recommendation 16 and existing travel‑rule standards; details may be further refined by the new guidance now under consultation.)*
• FATF is issuing implementation guidance for the updated Recommendation 16, which already increased obligations regarding payment transparency, including more granular beneficiary data and expanded...
• Cross‑border payments and value transfers above 1,000 USD/EUR are expected to include additional mandatory beneficiary information, such as beneficiary name, account or unique reference, and at least...
• Beneficiary institutions are given enhanced responsibilities to use travel‑rule information (not just receive it) for transaction monitoring, including detecting misdirected payments and indicators...
• The revised travel rule continues to apply to both traditional wire transfers and value transfers involving virtual assets, reinforcing that Virtual Asset Service Providers (VASPs) must collect,...

Key dates

TBD (from AMLA operational go‑live date in 2025–2026)

- AMLA formally designates its first batch of directly supervised obliged entities at EU level, potentially including entities identified under this circular

25 June 2026

- CSSF publishes Circular 26/914 identifying obliged entities eligible for direct supervision by AMLA and setting the framework for Luxembourg’s contribution to AMLA’s selection and supervisory process

TBD (periodic, post‑AMLA go‑live)

- Periodic reviews by AMLA and the CSSF of eligible entities’ status and updates to the list of entities subject to, or proposed for, direct AMLA supervision

Suggested considerations

• Determine whether your firm is likely to fall within the “eligible for AMLA direct supervision” perimeter by assessing your cross‑border footprint, ML/TF risk profile, group structure, and relative size against AMLA’s high‑risk and cross‑border criteria.
• Review and update the firm‑wide AML/CFT risk assessment to ensure it is robust, data‑driven, and aligned with an EU‑level supervisory perspective, including explicit consideration of cross‑border risks, complex group structures, and high‑risk products.
• Strengthen AML/CFT governance and oversight, including Board and senior management reporting, to demonstrate clear ownership of ML/TF risk, documented risk appetite, and effective challenge consistent with what AMLA expects from directly supervised entities.
• Review and, where necessary, enhance customer due diligence, transaction monitoring, screening and suspicious activity reporting frameworks to withstand more intrusive and harmonised EU‑level scrutiny.
• Map and document cross‑border business lines and passporting activities (branches, agents, tied intermediaries, distributors) to ensure you can provide complete and up‑to‑date information to the CSSF and AMLA on request.

What changed

• - The CSSF formally identifies Luxembourg “obliged entities” under AML/CFT law that are potentially eligible for direct AMLA supervision, clarifying which categories of firms fall into the EU‑level...
• The circular operationalises, at CSSF level, the EU allocation mechanism for direct supervision, building on Regulation (EU) 2024/… establishing AMLA and the forthcoming directly applicable AML...
• The CSSF establishes a process for providing information to AMLA on Luxembourg obliged entities (e.g. size, cross‑border activities, risk profile) to support AMLA’s periodic selection and review of...
• The circular clarifies that CSSF‑supervised entities identified as “eligible” remain under CSSF supervision unless and until AMLA formally designates them for direct supervision, at which point AMLA...
• The circular anticipates enhanced data and reporting requirements for entities assessed as eligible for AMLA direct supervision, including more granular information on cross‑border business,...

Key dates

27 October 2022

- Circular CSSF 22/822 was issued, establishing the framework for using FATF statements on high-risk jurisdictions and jurisdictions under increased monitoring

19 June 2026

- The annex was updated to this version date, reflecting the current FATF jurisdiction lists and associated risk posture

22 June 2026

- CSSF published the annex on its website, making the updated reference document operationally relevant for supervised firms

Suggested considerations

• Review your AML/CFT country-risk methodology and update it to reflect the 19 June 2026 FATF/CSSF jurisdiction list.
• Re-screen customers, beneficial owners, counterparties, and transactions against the updated high-risk and monitored jurisdiction lists.
• Apply enhanced due diligence for relationships and transactions involving high-risk jurisdictions, and escalate where counter-measures may be required.
• Reassess risk ratings for customers linked to jurisdictions under increased monitoring and document the rationale for any continued onboarding, retention, or exit decisions.
• Update automated screening rules, transaction-monitoring scenarios, and onboarding checklists so they use the current CSSF annex version.

What changed

• - CSSF republished the annex to Circular CSSF 22/822 in a Version of 19 June 2026, meaning firms should treat this as the current Luxembourg reference point for FATF jurisdiction screening and...
• The annex distinguishes between high-risk jurisdictions subject to enhanced due diligence and, where appropriate, counter-measures, and jurisdictions under increased monitoring that require...
• The publication incorporates the FATF’s current statements on jurisdictions with strategic AML/CFT/CPF deficiencies, which is the basis for operational country-risk controls used by...
• The related Circular CSSF 22/822 remains the framework document that instructs professionals to use FATF statements when assessing jurisdictional ML/TF/PF risk.

Suggested considerations

• Register for 20 May 2026 public hearing to engage directly on practical application across group structures.[https://www.amla.europa.eu/events/public-hearing-draft-rts-group-wide-minimum-requirements-and-additional-measures-subsidiaries-and-2026-05-20_en]
• Assess current group-wide AML/CFT frameworks against proposed minimums, identifying gaps in third-country controls, risk consolidation, and data sharing protocols.

What changed

• - Group-wide AML/CFT frameworks: Establishes minimum standards for design and implementation across groups, including cross-border structures and third-country operations, to enable consolidated...
• Third-country subsidiaries and branches: Introduces additional measures for entities in non-EU countries, extending requirements beyond traditional groups to other...
• Information sharing and parent identification: Defines provisions for intra-group data sharing and criteria to identify the EU parent undertaking when multiple entities report to a third-country head...
• Interlinked mandates: Cross-references obligations between Articles 16(4) and 17(3) for complementary requirements on organizational...

Key dates

Later in 2026

- Final adoption of guidelines and technical standards

16 April 2026

- Consultation launched

20 May 2026, 10:00–12:00 CET

- Public hearing on draft RTS on group-wide requirements

28 May 2026, 10:00–12:00 CET

- Public hearing on draft Guidelines on business-wide risk assessment

15 July 2026 Deadline

- Consultation deadline for submissions

Suggested considerations

• *Immediate (by 15 July 2026):
• Review draft Guidelines and assess alignment with current BWRA practices
• Identify gaps between existing risk assessment frameworks and proposed minimum requirements
• Prepare formal consultation responses, particularly if your organization operates in non-financial sectors
• Register for relevant public hearings (28 May for BWRA Guidelines; 20 May for group-wide RTS) to engage directly with AMLA

What changed

• The draft Guidelines introduce four minimum requirements for conducting adequate business-wide risk assessments applicable to all obliged entities. The framework mandates that entities:
• Identify risk exposure across their business model, customers, products, services, transactions, delivery channels, and geographical exposure
• Maintain consolidated risk views across group structures, eliminating silos between branches and subsidiaries
• Utilize internal and external data sources to build comprehensive risk landscapes, including monitoring customer behavior changes and tracking international typologies
• Apply proportionality based on entity size, business model, and risk profile, while ensuring consistent application of policies across the organization The guidelines specifically address evaluation...

Key dates

1 April 2026

Circular CSSF 26/909 published; immediate application of ESMA competence guidelines.; [User-provided content]

Suggested considerations

• Assess Staff Competence: Implement ESMA-guided evaluations (e.g., exams, certifications) for all relevant personnel handling crypto services; document results in governance frameworks.
• Update Policies and Training: Integrate competence criteria into HR, onboarding, and annual reviews; roll out MiCA-specific training on reporting, breaches, and governance.
• Licensing Dossier Enhancement: Include competence attestations in CSSF applications; appoint dedicated compliance/risk officers with verified qualifications.
• Ongoing Monitoring: Conduct regular audits, penetration tests, and incident planning; confirm compliance annually via management body statements.
• Early CSSF Engagement: Schedule dialogues and info sessions; create MiCA readiness scorecards for board and regulator discussions.

What changed

• - Adoption of ESMA Guidelines: CSSF mandates application of ESMA's criteria for evaluating staff knowledge and competence in crypto-asset services, including roles in custody, trading, portfolio...
• Assessment Framework: Firms must implement standardized tests and processes to verify staff qualifications, aligning with MiCA Article 62 on CASP authorization, focusing on technical crypto...
• No New Standalone Rules: This circular builds on prior CSSF MiCA circulars (e.g., 25/890 on crypto-asset classification), integrating competence checks into licensing dossiers and ongoing supervision.

Key dates

27 October 2022

- Original Circular CSSF 22/822 issued

27 October 2025

- Previous version superseded

17 February 2026

- Current version effective (Annex of Circular CSSF 22/822)

23 February 2026 Deadline

- CSSF annual AML/CFT questionnaire launch (related compliance reporting deadline)

Suggested considerations

• *For High-Risk Jurisdictions:
• Apply enhanced due diligence and monitoring measures to business relationships and transactions with designated jurisdictions
• Increase the frequency and timing of transaction controls
• Select transaction patterns requiring further examination and obtain detailed information on transaction purposes
• Maintain enhanced mechanisms for reporting suspicious activity to the FIU

What changed

The current version (17 February 2026) represents the most recent update to the CSSF's FATF-aligned jurisdiction risk framework. Based on the available search results, the document establishes two primary regulatory categories: High-Risk Jurisdictions (Category 1): Jurisdictions designated by FATF as having strategic deficiencies in their AML/CFT regimes, requiring enhanced due diligence and, where appropriate, counter-measures.

Key dates

2026 (exact date TBD) Deadline

AML/CFT standardised data collection exercise; Firms must submit required data during this period; preparation recommended immediately given today's date (12 February 2026)

20 January 2026 Deadline

Issuance of related Circular 26/906; Establishes governance baselines (e.g., compliance independence, risk proportionality) informing data collection expectations

26 January 2026

CSSF AML/CFT Conference for Specialised PFS; Provided updates on sub-sector risks, terrorist financing reviews, and FIU insights relevant to data preparation

28 January 2026 Deadline

Conference materials published; Available for download to guide compliance alignment

Suggested considerations

• Assess and document AML/CFT data readiness: Inventory current risk assessments, transaction monitoring logs, KYC processes, SAR filings, and third-party oversight records in standardized formats; map to proportionality factors (e.g., transaction volumes, outsourcing).
• Update governance and controls: Ensure compliance functions have independence, direct board reporting, and audit coverage of AML/CFT; test ICT resilience for monitoring continuity.
• Conduct internal reviews: Perform gap analyses against Circular 26/906 (e.g., fund safeguarding, escalation protocols) and recent conference topics (e.g., terrorist financing, tax indicators); remediate deficiencies with board-approved plans.
• Prepare for submission: Designate resources for data compilation; cooperate fully with CSSF/FIU requests, including transfer-of-funds information under EU 2015/847.
• Engage auditors: Leverage approved auditors for validation of AML/CFT effectiveness ahead of collection.

What changed

• - Introduction of standardized AML/CFT data collection: CSSF mandates uniform reporting formats for collecting data on AML/CFT risks, controls, and practices across supervised sectors, building on...
• Alignment with ongoing AML/CFT enhancements: Complements recent governance-focused circulars (e.g., Circular 26/906 on central administration and risk management for payment/e-money institutions) by...
• No explicit new obligations beyond preparation for data submission, but implies deeper integration of tax-related AML indicators and sub-sector risk updates, as seen in related CSSF activities.

Key dates

30 April 2025 Deadline

- CSSF re-submission deadline post-validation for 2025; analogous for 2026 if errors detected

May 2025

- ESAs' second-round validation for 2025; expect similar for 2026 with potential re-submissions

1 April 2025 to 15 April 2025

- Initial 2025 submission window via eDesk (for context; 2026 window likely similar, pending confirmation)

31 December 2025

- Reference date for 2026 RoI submission (all contractual arrangements up to this date)

11 February 2026

- Publication date of this error guidance (last updated 10/02/2026)

Suggested considerations

• Assign "DORA Reporting" role in eDesk to dedicated employee(s) per user guide.
• Communicate LEI code to CSSF line supervisor prior to first submission to enable upload.
• Prepare RoI in plain-CSV files within .zip following ESAs' folder structure/file naming (reference date '2025-12-31'); include all tables in FilingIndicators.csv (even empty, set to 'true').
• Test submissions against listed error codes (e.g., ICTO007 for LEI, identification mismatches); resolve per guidance sections (e.g., Sections 3.2.2, 5.1.2, 6).
• Consult ESAs' EBA resources (data point model, validation rules, FAQs) and CSSF guides (e.g., submission guide, guidance tables).

What changed

• - Enhanced validation checks for the 2026 RoI submission: Applies ESA-defined checks (last updated April 2025) to more data fields to improve data quality, compared to prior cycles.
• Specific error resolutions detailed, including requirements for LEI code communication to CSSF beforehand, correct reference date ('2025-12-31') in file naming, plain-CSV files in predefined .zip...
• Mandatory inclusion of all tables (even empty) in FilingIndicators.csv set to 'true', with matching identification codes across parent-child records.
• Builds on prior CSSF guides, emphasizing eDesk role "DORA Reporting" assignment and ESAs' technical standards. No new regulatory requirements under DORA itself; this refines technical submission...

Key dates

20 January 2026

- Publication date of Circular CSSF 26/906

30 June 2026 Deadline

- Compliance deadline: Institutions must assess/review central administration, internal governance, and risk management frameworks to ensure full compliance

Suggested considerations

• Gap analysis: Assess current frameworks against circular requirements on management bodies, internal controls, conflicts of interest, product approval, and fund safeguarding.
• Updates and notifications: Review/revise governance arrangements (e.g., policies, structures); notify CSSF of management body members, compliance officers, and internal auditors with required documentation (professional experience, police records, etc.).
• Implementation: Establish robust risk identification/management/monitoring/reporting processes, internal controls, and proportional arrangements (e.g., IT, outsourcing).
• Documentation: Develop conflicts policy, new product approval procedures, and safeguarding rules; ensure management body authorization.
• Ongoing: Maintain sound/prudent management amid growth; integrate with Law of 10 November 2009 requirements.

What changed

• The circular consolidates and updates governance rules, focusing on:
• Management bodies: Responsibilities, composition, qualifications, organization, and functioning, including CSSF authorization of members based on professional experience, standing (e.g., police...
• Internal control functions: Responsibilities, characteristics, organization, and execution of work for compliance officers and internal auditors, with notifications to CSSF including detailed...
• Conflicts of interest: Key requirements for a management policy applicable to all staff and management body members.
• New product approval: Defined key steps in the process.

Key dates

20 January 2026

Publication date of Circular CSSF 26/906

30 June 2026 Deadline

Compliance deadline; Institutions must assess, review, and ensure their central administration, internal governance, and risk management frameworks fully comply with the circular

Suggested considerations

• Assess and update governance frameworks: Review central administration location, board/management responsibilities, risk strategy, AML/CFT policies, compliance charter, and funds safeguarding principles to align with the circular.
• Confirm control functions: Ensure compliance function (CCO) has independence, resources, direct board access, and authority for investigations; justify/secure CSSF approval for part-time/dual roles.
• Implement operational safeguards: Establish daily reconciliations (or justified weekly), segregation/insurance for client funds, system access controls (4-eyes, board validation for significant movements), and third-party due diligence/monitoring.
• Document proportionality: Tailor governance to business risks (staff, volumes, products, outsourcing); update new product approval, conflicts policies, and business continuity/incident reporting.
• Retain records and report: Board-approve all key policies; prepare for CSSF inspections on outsourcing (per Circular CSSF 22/806) and ICT risks.

What changed

• - Consolidation and repeal: Replaces outdated circulars with unified requirements under the amended Law of 10 November 2009 on payment services, covering central administration (decision-making must...
• Governance enhancements: Board approves strategy, risk appetite, AML/CFT policies, outsourcing, and information security; management implements via procedures; proportionality based on business...
• Operational controls: Strict access to systems (need-to-know, least-privilege, 4-eyes validation); counterparty due diligence for custodians/insurers; full responsibility for agents, distributors,...
• AML/CFT focus: Elevates compliance function independence, direct board reporting, risk-based resourcing, and oversight of third parties/opaque structures to close gaps exploited by criminals.

Suggested considerations

• For the named population: Comply with any sanction terms (e.g., pay fines, implement remediation plans, or cease certain activities), and report to CSSF as required; appeal if applicable under Luxembourg administrative law.
• Update internal policies, train staff on enforcement precedents, and ensure robust reporting under Circular CSSF 19/726 or Transparency Law obligations.

What changed

No new regulatory changes or requirements are introduced in this publication, as it is an enforcement notice rather than a circular or guideline. It serves as a disclosure of an ongoing or concluded enforcement case, aligning with CSSF's practice of publishing sanction details to deter non-compliance and inform the market, without altering existing rules.

Key dates

December 24, 2025

- Circular publication date

December 31, 2025

- Reference date for the survey

January 30, 2026 Deadline

- Deadline for transmitting average covered deposits data to the Single Resolution Board

Suggested considerations

• *Calculate covered deposits as defined in Article 163 of the 2015 law, including balance and accrued interest (even if not yet due)
• *Report eligible deposits after applying exclusions under Article 172 of the 2015 law, including exclusions for financial institutions and life insurance products
• *Distinguish deposit types by reporting:
• Total eligible deposits (field 201)
• Eligible deposits in omnibus accounts, fiduciary accounts, trusts, sub-accounts, and segregated accounts (field 0226)

What changed

The circular explicitly states that no substantive changes have been made to the survey process compared to previous quarters. The only modifications are administrative: the reference date (December 31, 2025) and the submission deadline (January 30, 2026). The specifications for data collection, definitions of covered and eligible deposits, and reporting methodologies remain unchanged from prior circulars, particularly Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35.

Suggested considerations

• Conduct annual exposure assessments to sanctions risks and circumvention; update policies accordingly.
• Appoint senior management/board-level responsibility for approving and overseeing sanctions strategy, including annual reviews and deficiency reporting.
• Implement reliable screening systems for customers, transactions, and lists; define screenable datasets; test systems regularly for effectiveness (e.g., immediate freezing, accurate hits).
• Provide documented training to relevant staff on sanctions, institutional exposure, and internal processes.
• Establish processes for immediate action on matches: suspend transfers, freeze assets, report to Ministry of Finance/CSSF/FIU without delay; maintain whitelists only under strict conditions.

What changed

• - Institutions must develop, implement, and maintain up-to-date policies, procedures, and controls for identifying, investigating, and applying restrictive measures without delay, including risk...
• Management body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and...
• Screening and monitoring requirements: Maintain updated sanctions lists with immediate integration of changes; screen customer base, transactions, and datasets accurately; enable immediate...
• Training and testing: Deliver regular, documented role-specific training; perform ongoing system testing for screening calibration, list accuracy, transaction monitoring effectiveness, and reporting.
• Proportionality applies based on institution's size, activities, and exposure; PSPs and CASPs explicitly addressed with tailored controls.