Extract from the CSSF Newsletter No 300 – January 2026
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Survey on the amount of covered deposits held on 31 December 2025
Circular CSSF-CPDI 25/49 is a **mandatory quarterly reporting requirement** for Luxembourg credit institutions and postal financial service providers to submit data on covered deposits as of December 31, 2025. This survey directly feeds into the Single Resolution Fund's annual target level calculation and the Luxembourg deposit guarantee scheme's contribution assessments, making it essential for regulatory compliance and fund management.
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.
What You Need To Do
- *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)
Key Dates
January 30, 2026 - Deadline for transmitting average covered deposits data to the Single Resolution Board DEADLINE
December 31, 2025 - Reference date for the survey
December 24, 2025 - Circular publication date
Compliance Impact
Urgency: HIGH
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Update of Circular CSSF 24/850 on the practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS, as well as the engagement of the réviseurs d’entreprises agréés (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
Circular CSSF 25/903 updates Circular CSSF 24/850, refining practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg regarding their annual descriptive report, self-assessment questionnaire, and the roles of approved statutory auditors (réviseurs d’entreprises agréés). It specifies requirements for auditors' engagement, management letters, and separate annual reports. This matters for support PFS as it enhances supervisory oversight, ensures consistent reporting quality, and strengthens internal controls, directly impacting compliance and audit processes amid CSSF's focus on robust PFS supervision.
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What Changed
Updates to Descriptive Report and Self-Assessment Questionnaire: Refines content, format, and submission requirements for support PFS's annual submissions, emphasizing more detailed disclosures on operations, risks, and controls (building on CSSF 24/850).
Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for reviewing support PFS reports.
Management Letter
What You Need To Do
- *Review and Update Processes
- *Engage/Confirm Auditors
- *Implement Templates and Testing
- *Training and Governance
- *Submit on Time
Key Dates
1 January 2026 - Effective Date Applies to annual reporting cycles starting for financial year 2025 onwards.
30 April (annually) - Submission Deadline Support PFS must submit descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF by 30 April following the financial year-end (first applicable: 30 April 2026 for FY 2025). DEADLINE
31 December 2025 - Preparation Milestone Auditors must be engaged and initial scoping completed by year-end 2025 for FY 2025 compliance. DEADLINE
Compliance Impact
Urgency: High. This is high urgency for support PFS due to the impending 30 April 2026 deadline for FY 2025 submissions, with non-compliance risking supervisory fines, license reviews, or reputational damage under CSSF's PFS enforcement regime. It matters as it tightens audit accountability, potenti
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Repeal of Circular CSSF 19/731 regarding the documents to be submitted on an annual basis by credit institutions.
Circular CSSF 25/902 repeals Circular CSSF 19/731 (as amended by Circular CSSF 19/710), which previously detailed annual document submission requirements for credit institutions, shifting to a dynamic list published on the CSSF website. This matters because it streamlines compliance by centralizing and updating requirements online, reducing reliance on static circulars while maintaining submission obligations. Credit institutions must transition to the new process to avoid disruptions in prudential reporting.
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What Changed
Repeal of prior circulars: Circular CSSF 19/731 and its amendment via Circular CSSF 19/710 are fully repealed, eliminating the fixed list of annual submission documents.
Shift to website-based guidance: The updated list of required documents, affected entity categories, electronic submission channels, and deadlines is now published on the CSSF’s Prudential reporting for credit institutions webpage, including an interactive summary table for determining applicable submissions.
Ongoing obligations
What You Need To Do
- Review the CSSF Prudential reporting webpage (https://www
- Update internal reporting processes, templates, and workflows to reference the website instead of the repealed circular
- Confirm ongoing annual submissions via specified electronic channels; test interactive table for applicability to the institution's profile
- Archive references to Circular CSSF 19/731 in policies and train staff on the change
Key Dates
23 December 2025 - Publication and effective date of Circular CSSF 25/902, repealing Circular CSSF 19/731; transition to website-based list begins.
12 December 2019 - Original issuance of repealed Circular CSSF 19/731 (archived on 23 December 2025).
1 January 2025 ).
Compliance Impact
Urgency: Medium – The repeal does not alter core submission obligations but requires procedural updates to avoid non-compliance with potentially evolving lists under CRR3 alignments. It matters for operational efficiency, as failure to adapt could lead to missed deadlines or incorrect submissions, e
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Practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS.Engagement of the réviseurs d’entreprises agréés (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
Circular CSSF 24/850, as amended by Circular CSSF 25/903, establishes practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg to submit annual descriptive reports and self-assessment questionnaires, while also defining the roles of approved statutory auditors (réviseurs d’entreprises agréés) in issuing management letters and separate reports. This guidance standardizes supervisory reporting and audit processes to enhance oversight of support PFS, which provide essential back-office services to authorized PFS. It matters because non-compliance risks supervisory sanctions, reputational damage, and operational disruptions for entities reliant on support PFS structures.
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What Changed
Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management, internal controls, and operational metrics specific to support PFS activities (e.g., IT services, administrative support, custody).
Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separa
What You Need To Do
- Annual Reporting Cycle
- February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report
- Governance Updates
- Auditor Coordination
- Record-Keeping
Key Dates
31 March annually - Deadline for submission of descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF (first applicable for FY 2024 reporting due 31 March 2025). DEADLINE
1 January 2025 - Effective date of original Circular CSSF 24/850.
15 December 2025 - Effective date of amendments in Circular CSSF 25/903, applicable to 2025 reporting cycle onwards.
End of February annually - Support PFS must engage auditors and provide necessary data to enable timely report preparation. DEADLINE
Compliance Impact
Urgency: High – This is a recurring annual obligation with a firm 31 March deadline, where delays trigger automatic CSSF notifications and potential fines (up to €250,000 per Law 1993). It matters for support PFS as it intensifies scrutiny on operational resilience in a post-SFI (2021) landscape, wh
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Press release 25/21(published on 22 December 2025, updated on 31 December 2025)
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Press release 25/20
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relating to specialised investment funds, investment companies in risk capital and undertakings for collective investment subject to Part II of the Law of 17 December 2010
Circular CSSF 25/901 consolidates and modernizes the supervisory framework for Luxembourg specialised investment funds (SIFs), investment companies in risk capital (SICARs), and undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs), including their sub-funds. It streamlines investment rules, diversification limits, borrowing, disclosures, and risk management while enhancing flexibility for sophisticated investors and formalizing prior informal guidance, reducing regulatory complexity without compromising investor protection.
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What Changed
Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to 50% per issuer/UCI/asset or 70% per infrastructure investment for well-informed/professional investor funds, with CSSF derogations possible on justification. Limits apply on assets/commitments basis with look-through for intermediary vehicles.
SICAR-specific rules: Confirms risk capital investments (e.
What You Need To Do
- Review and update fund documents (e
- Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified
- Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries
- For retail-marketed funds
- Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts
Key Dates
late 2025 /early 2026 publications, but no explicit dates are provided.
Compliance Impact
Urgency: High – Formalizes prior informal guidance into binding rules with enhanced flexibility but stricter retail protections and disclosure mandates, requiring immediate document reviews/updates for non-compliant SIFs/SICARs/Part II UCIs to avoid supervisory scrutiny or authorization issues; crit
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Revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment (“UCI”) are subject
Circular IML 91/75, as amended up to CSSF Circular 25/901, consolidates and modernizes the supervisory framework for Luxembourg Part II UCIs, SIFs, and SICARs, refining rules on diversification, borrowing, risk-spreading, and disclosures while tailoring requirements to investor profiles. It matters because it streamlines fragmented regulations, enhances fund competitiveness, and formalizes CSSF expectations without mandating immediate changes for pre-existing funds, reducing compliance burdens while promoting transparency and flexibility. This update aligns administrative practices with market realities, repealing outdated circulars to eliminate ambiguity.
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What Changed
Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs.
Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with justification; applies look-through for intermediary vehicles; harmonizes ramp-up (up to 12 months for liquid strategies,
What You Need To Do
- Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e
- Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications
- Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified
- Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance
- No immediate changes required for pre-19 Dec 2025 funds, but proactive alignment recommended to avoid future issues
Compliance Impact
Urgency: Medium – Not critical as existing funds are grandfathered with no retroactive changes required, but high relevance for new launches or material updates post-19 Dec 2025. It matters for operational efficiency (streamlined rules reduce fragmentation) and investor protection (tailored risks/di
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Rules applicable to undertakings for collective investment when they employ certain techniques and instruments relating to transferable securities and money market instruments
Circular CSSF 08/356, as amended by Circular CSSF 25/901, establishes detailed rules for Luxembourg undertakings for collective investment (UCIs), including UCITS and alternative investment funds (AIFs), on the use of techniques and instruments relating to transferable securities and money market instruments, such as securities lending, repo transactions, and over-the-counter (OTC) derivatives. It matters because it ensures investor protection, risk management, and market stability by imposing strict eligibility, collateral, and operational requirements, aligning Luxembourg funds with EU standards under UCITS and AIFMD directives. Compliance is critical for Luxembourg-domiciled funds engaging in these activities to avoid regulatory sanctions and operational disruptions.
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What Changed
The original Circular CSSF 08/356 (2008) transposed UCITS III requirements on eligible techniques like securities lending and repos. The amendment via Circular CSSF 25/901 (issued in 2025) introduces updates to reflect post-Brexit adjustments, enhanced ESG considerations in collateral eligibility, stricter counterparty risk limits for OTC derivatives, and improved transparency in reporting. Key changes include:
Expanded collateral rules: Collateral must now include sustainable assets meeting SFD
What You Need To Do
- *Policy Review & Update
- *Risk Management Systems
- *Counterparty Due Diligence
- *Operational Setup
- *Reporting & Disclosure
Key Dates
23 December 2008 - Original Circular CSSF 08/356 effective date for UCITS III implementation.
21 July 2011 - Partial updates for UCITS IV alignment.
22 July 2013 - Extension to AIFs under AIFMD transposition.
15 October 2025 - Issuance of amending Circular CSSF 25/901.
01 January 2026 - Effective date for amendments (e.g., new collateral rules, reporting formats).
Compliance Impact
Urgency: High - Immediate relevance for funds actively using these techniques (common in fixed-income and equity strategies for yield enhancement). Non-compliance risks CSSF fines (up to 5% of NAV), temporary prohibitions on techniques, or fund suspension. With the 01 January 2026 effective date rec
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amending Circular CSSF 22/811.Authorisation and organisation of entities acting as UCI administrators.
Circular CSSF 25/900, issued on 16 December 2025, amends Circular CSSF 22/811 to clarify governance principles, authorisation requirements, and operational standards for UCI (Undertakings for Collective Investment) administrators in Luxembourg, while reforming annual reporting obligations. It matters because it strengthens supervisory oversight, aligns with DORA for ICT outsourcing, and simplifies reporting to enhance efficiency and compliance in the fund administration sector.
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What Changed
Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses governance, internal controls, operational organization, and risk management; detailed instructions are now on the CSSF website.
Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authori
What You Need To Do
- Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations
- Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025
- Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750)
- For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882
Key Dates
16 December 2025 - Issuance date; repeal of Annex B of Circular CSSF 22/811 effective immediately.
January 2025 - DORA entry into force, applying to ICT outsourcing for in-scope UCIAs.
31 December 2025 - New reporting framework (SAQ and updated modalities) applies to all financial years ending on or after this date.
Compliance Impact
Urgency: High - Immediate repeal of prior reporting Annex requires prompt process updates; new framework applies to FY 2025 year-ends (just past as of Jan 2026), risking supervisory scrutiny or penalties for non-compliance; DORA alignment adds operational resilience pressure amid ongoing CSSF focus
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Authorisation and organisation of entities acting as UCI administrators
Circular CSSF 22/811, as amended by Circular CSSF 25/900, establishes CSSF requirements for the authorisation, governance, internal organisation, and oversight of entities acting as UCI (Undertakings for Collective Investment) administrators in Luxembourg. It matters because it standardises practices amid regulatory, technological, and market evolutions, ensuring robust controls, risk management, and supervision for fund administration activities critical to Luxembourg's fund industry.
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What Changed
Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure; application must include details per Annex A, with ongoing updates for substantial changes.
Scope of UCI Administration: Defines three core functions—registrar, NAV calculation/accounting, and client communication—requiring only one designated service provider per function per UCI (or compartment); UCI/IFM may p
What You Need To Do
- Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated
- Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function
- For delegations
- Conclude written contracts with UCI/IFM; submit annual UCIA activity reports
Compliance Impact
Urgency: High – Non-compliance risks CSSF sanctions, as authorisation is prior and ongoing; critical for Luxembourg fund ecosystem given evolutions in tech/markets/DORA. Firms must act promptly if unauthorised or misaligned, especially with annual reporting since 2023 and DORA integration; impacts o
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Application of the Guidelines of the European Banking Authority on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (EBA/GL/2025/03)
Circular CSSF 25/899 mandates the application of EBA Guidelines (EBA/GL/2025/03) on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (CRR), specifying conditions for reducing the risk weight from 150% to 100% on qualifying exposures. This matters for Luxembourg credit institutions as it directly impacts capital requirements for real estate lending, promoting safer lending practices while aligning with Basel III standards via CRR3 implementation.
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What Changed
Introduces precise definitions for CRR Article 126a(2) terms, enabling 100% risk weight (instead of 150%) for ADC exposures to residential property if conditions are met: at least 50% of total contracts as pre-sale/pre-lease agreements with substantial cash deposits (e.g., ≥10% of sale price for sales, ≥3x monthly lease for leases), or equivalent financing/sale-lease combos; plus obligor equity ≥25% of completed property value.
Mandates "sound standards for lending and credit monitoring" alongsi
What You Need To Do
- Review and classify ADC exposures against EBA-defined criteria (e
- Update internal policies, risk assessment models, and credit approval processes to incorporate "sound lending standards" and EBA specifications, including social housing carve-outs
- Recalculate capital requirements under standardized credit risk approach; report changes via CRR disclosures
- Maintain documentation proving compliance (e
- Institutions must "make every effort to comply" per EBA Regulation Article 16(3)
Key Dates
4 November 2025 - EBA Guidelines (EBA/GL/2025/03) apply across EU (two months post-publication on 27 June 2025 in all official languages).
1 December 2025 - CSSF Circular 25/899 published, requiring immediate compliance preparation for Luxembourg firms. DEADLINE
Compliance Impact
Urgency: High – Firms with significant ADC portfolios face immediate capital relief opportunities (50bp risk weight reduction) but risk non-compliance penalties if processes aren't updated by early 2026, especially post-CRR3 rollout; misclassification could inflate capital needs amid ongoing Basel i
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Press release 25/19
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Press release 25/18
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Fonds de garantie des dépôts Luxembourg (FGDL) – Method for calculating the ex-ante contributions pursuant to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and of certain investment firms
Circular CSSF-CPDI 25/48, published on 13 November 2025, updates the methodology for calculating ex-ante contributions to the Fonds de garantie des dépôts Luxembourg (FGDL), Luxembourg's deposit guarantee scheme, by aligning risk adjustments with EBA Guidelines and introducing a zero floor for certain calculation components. This matters for Luxembourg credit institutions as it refines risk-sensitive contributions to meet DGSD target levels for two compartments (0.8% and an additional 0.8% of covered deposits), ensuring financial stability while promoting supervisory convergence across the EU.
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What Changed
Risk Adjustment Updates (Annex 2): Increases weight of 'Return on assets' (ROA) risk indicator from 7.5% to 10%; decreases 'Deposit-size Risk' from 15% to 12.5%; adjusts sliding scale bounds for indicators like leverage ratio (3%-9%), capital coverage ratio (100%-200%), LCR/NSFR (100%-200%), NPL ratio (0%-3%), and others per Table 2, aligning with minimum EBA Guidelines weights totaling 75% plus national flexibility.
Formula Component Floor (Annex 1): Introduces a zero floor for Component 1 (max
What You Need To Do
- Review and update internal systems/models for contribution calculations to incorporate new risk weights, bounds (Table 2), zero floor for Component 1, and revised formulas in Annexes 1-2
- Validate data reporting for risk indicators (e
- Prepare for FGDL invoices reflecting compartment-specific rates; monitor covered deposits for surveys (e
- Conduct gap analysis against repealed circulars (20/21, 23/34); update policies for mergers, deposit changes, and gap fillings (Γ_λ)
Compliance Impact
Urgency: High – Institutions must promptly recalibrate risk models ahead of 2026 contributions to avoid miscalculations, penalties, or underfunding risks, as this directly impacts prudential contributions amid ongoing DGSD buildup to 2026; non-alignment with EBA could trigger CSSF scrutiny. Failure
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Fonds de garantie des dépôts Luxembourg (FGDL) – Method for calculating the ex-ante contributions pursuant to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and of certain investment firms
Circular CSSF-CPDI 25/48 updates the methodology for calculating ex-ante annual contributions to the Fonds de garantie des dépôts Luxembourg (FGDL), Luxembourg's deposit guarantee scheme, specifically for the target levels in Articles 179 and 180 of the Law of 18 December 2015 on the failure of credit institutions and certain investment firms. This matters because it introduces a risk-adjusted contribution model aligned with EBA Guidelines, shifting from purely deposit-based calculations to ones incorporating institution-specific risk factors, potentially increasing contributions for higher-risk banks while promoting stability in the scheme's funding.
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What Changed
Modified Contribution Formula: Replaces prior methods (e.g., from Circulars CSSF-CPDI 16/01, 17/06, 20/21) with a new structure: Component 1 proportional to covered deposits growth (Γ_{j,k}) at 0.8% base rate, plus a flat add-on (T_j D_{j-2,k}) for target shortfalls, adjusted by a uniform factor μ per compartment, and multiplied by a new risk adjustment factor (ARW_{j,k}).
Risk Adjustment Introduction: ARW is calculated using a weighted score (minimum 75% on EBA core categories, plus 12.5% depos
What You Need To Do
- Data Reporting
- Internal Calculations
- Risk Monitoring
- Systems Update
Key Dates
13 November 2025 - Circular publication date by CSSF.
31 December 2025 - Reference date for covered deposits survey (per related Circular CSSF-CPDI 25/49).
2026 - First application year for new methodology (contributions for year j=2026 based on j-1=2025 data; invoices issued by FGDL).
for 2026 cycle.
Compliance Impact
Urgency: High - Affects 2026 contributions directly, requiring immediate data readiness and modeling by Q1 2026; non-compliance risks penalties, inaccurate payments, or higher costs from poor risk scores. Matters for capital planning as riskier profiles face uplifts, emphasizing proactive risk manag
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Update of Circular CSSF 22/821 on the Long Form Report, as amended by Circulars CSSF 23/845 and CSSF 24/865
Circular CSSF 25/897 updates Circular CSSF 22/821 on the Long Form Report (LFR) for credit institutions, further aligning the self-assessment questionnaire (SAQ) with current supervisory priorities such as ML/FT risks and organizational aspects. This matters because it refines reporting to reduce redundancies, enhance transparency in REA assessments, and reflect evolving prudential focuses since prior amendments via Circulars CSSF 23/845 and 24/865, ensuring institutions' reports better support CSSF oversight.
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What Changed
Introduces new modules in the revised SAQ to align with supervisory points of focus, building on prior expansions (e.g., credit/counterparty risk, liquidity risk, climate-related risks from CSSF 23/845).
Emphasizes REA's independent assessment in the AML/CFT report, requiring exhaustive, transparent evaluations of ML/FT risks across institutions, branches, majority-owned subsidiaries abroad, and tied agents; prohibits vague language (e.g., no "no serious weaknesses" phrasing) and mandates positi
What You Need To Do
- Complete and submit revised SAQ annually, incorporating new modules on supervisory focuses like ML/FT risks and providing detailed data to REA
- Authorized management
- Ensure AML/CFT report details methodologies (e
- Review prior LFR submissions against this update to align with suppressed redundancies and new emphases
Key Dates
31 October 2025 - Issuance date of Circular CSSF 25/897.
Three months after financial year-end - Annual submission deadline for SAQ to CSSF (unchanged from prior circulars). DEADLINE
Five months after financial year-end - Submission deadline for REA Reports (Financial Instruments and Funds Report; AML/CFT Report). DEADLINE
Six months after financial year-end - Aligned submission for REA management letter (per amendments in CSSF 23/845 to Circular 22/826).
Compliance Impact
Urgency: High - Institutions face immediate refinement needs for 2025 year-end reporting (e.g., SAQ due ~Q1 2026), with stricter REA scrutiny on AML/CFT transparency risking supervisory findings or enforcement if vague assessments persist; aligns with ongoing CSSF push for risk-focused oversight ami
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Long Form ReportPractical rules concerning the self-assessment questionnaire to be submitted by institutionsMission and related reports of the statutory auditors (réviseurs d’entreprises agréés)
**Circular CSSF 22/821** (as amended) fundamentally restructures how Luxembourg credit institutions report to the Commission de Surveillance du Secteur Financier (CSSF) by replacing the traditional Long Form Report with a digital **self-assessment questionnaire (SAQ)**, complemented by auditor-prepared reports. This shift represents a significant operational change that requires institutions to directly participate in prudential self-assessment while maintaining robust external audit oversight, making it essential for compliance and operational teams to understand new submission requirements and digital workflows.
What Changed
The circular introduces a three-component reporting framework that fundamentally alters the compliance landscape:
Self-Assessment Questionnaire (SAQ): A digital, annually-completed questionnaire that institutions must prepare directly, covering domains within CSSF and ECB prudential supervision competence
Agreed Upon Procedures (AUP) Reports: Reports prepared by approved statutory auditors (réviseurs d'entreprises agréés) on specific compliance areas
Separate REA Report on Financial Instruments
What You Need To Do
- *For Credit Institutions
- *Establish SAQ Governance
- *Data Preparation
- *Digital System Access
- *Module Completion
Key Dates
25 October 2022 - Circular CSSF 22/821 issued
31 December 2022 - Circular enters into application
Three months before financial year closure - SAQ becomes accessible through CSSF digital solution
Three months after financial year closure - Deadline for SAQ submission to CSSF DEADLINE
Five months after financial year closure - Deadline for REA reports submission DEADLINE
Compliance Impact
Urgency: HIGH
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Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services
Circular CSSF 07/325, as amended by Circulars CSSF 21/765, CSSF 22/827, and most recently CSSF 25/898, establishes supervisory requirements for EU credit institutions and investment firms operating in Luxembourg via branches or free provision of services (FOPS). It matters for compliance professionals as it defines CSSF's host authority role, notification obligations, reporting, and enforcement powers, ensuring alignment with CRD and MiFID II while adapting to evolving EU rules.
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What Changed
CSSF 21/765: Updated provisions following amendments to CSSF Regulation No 12-02, refining notification and operational requirements for branches and FOPS.
CSSF 22/827: Further amendments to align with CRD and MiFID II changes, including enhanced notifications for programme alterations (e.g., one-month prior written notice for changes in operations, services, or activities).
CSSF 25/898: Latest update (noted in CSSF Newsletter No 298, November 2025), incorporating recent legal/regulatory develop
What You Need To Do
- Notifications
- Supervision cooperation
Key Dates
One month before change effective date - Notify CSSF and home authority in writing of programme changes (e.g., operations, services, additional places of business) per CRD Article 36(3) and MiFID II Article 35(10).
Within 3 months of receipt - Home state authority communicates notification file to CSSF for branch/FOPS establishment.
Six months after financial year-end - Submit electronically signed SAQ (via eDesk), annual AML/CFT and conduct of business report (per Circular CSSF 19/731, to be repealed by CSSF 25/902), reviewed by REA.
Compliance Impact
Urgency: Medium - Matters due to recurring annual reporting (e.g., SAQ, AML/CFT within six months post-year-end) and prior notifications for changes, with CSSF enforcement powers (e.g., measures under LFS Article 46(2)) for non-compliance. Recent CSSF 25/898 update (Nov 2025) requires immediate revi
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Update of Circular CSSF 07/325 on Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services, as amended by Circulars CSSF 21/765 and CSSF 22/827
Circular CSSF 25/898 updates Luxembourg's supervisory framework for EU-origin credit institutions and investment firms operating in Luxembourg through branches or free provision of services. This amendment enhances the self-assessment questionnaire (SAQ) used by the CSSF to align supervisory oversight with current regulatory priorities, particularly adding UCI administration as a new thematic module. The update reflects the CSSF's evolving supervisory focus and requires affected institutions to demonstrate compliance with expanded assessment criteria.
What Changed
The circular introduces the following material modifications to Circular CSSF 07/325:
*New Supervisory Module
UCI administration** has been added as a thematic module to the self-assessment questionnaire, reflecting increased regulatory attention to fund administration practices.
*Enhanced Self-Assessment Framework**
Existing modules have been updated to better align with supervisory objectives and current regulatory priorities.
The revised SAQ now captures a broader range of supervisory point
What You Need To Do
- *Update Self-Assessment Processes
- Revise internal SAQ completion procedures to address the new UCI administration module
- Ensure all thematic modules reflect current supervisory expectations
- *Assess UCI Administration Compliance
- If the institution provides or is involved in UCI administration services, conduct a detailed assessment of compliance with CSSF expectations
Key Dates
31 October 2025 - Circular CSSF 25/898 published by the CSSF
19 December 2025 - Related modernization framework (Circular CSSF 25/901) entered into force for Part II UCIs, SIFs, and SICARs
No specific implementation deadline stated - Institutions should align their SAQ responses and compliance documentation with the updated framework immediately upon publication DEADLINE
Compliance Impact
Urgency: HIGH
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Press release 25/17
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Survey on the amount of covered deposits held on 30 September 2025
Circular CSSF-CPDI 25/47 mandates a regular survey by Luxembourg credit institutions on the amount of covered deposits as of **30 September 2025**, focusing on eligible and covered deposits under the Law of 18 December 2015 on deposit guarantee schemes. It matters because it ensures accurate reporting to the Conseil de protection des déposants et des investisseurs (CPDI) for FGDL (Fonds de garantie des dépôts Luxembourg) compliance, with detailed field-by-field instructions for complex accounts like omnibus and trusts.
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What Changed
This circular updates prior guidance (notably CSSF-CPDI 16/02 as amended by CSSF-CPDI 23/35) by specifying the survey reference date of 30 September 2025 and providing granular reporting fields for eligible deposits (e.g., exclusions for financial institution-like structures and life insurance products), covered deposits capped at €100,000 per person, and breakdowns by natural/legal persons, including shares in omnibus accounts, fiduciaries, trusts, sub-accounts, and segregated accounts. Key fie
What You Need To Do
- For omnibus/trust accounts, obtain and report shares of identifiable entitled persons, apportion by legal status of holder, and ensure fields like 0226 and 0255 reconcile
- Designated management reviews/approves data; transmit accurately to CSSF/CPDI, respecting prior circulars (e
- Exclude non-creditor accounts or those assimilated to financial institutions/life insurance
Key Dates
30 September 2025 - Reference date for snapshot of deposits, eligible deposits, and covered deposits.
6 October 2025 - Publication date of the circular by CSSF.
31 December 2025 ) imply prompt post-reference date filing to CSSF/CPDI; firms should confirm via full PDF.
Compliance Impact
Urgency: Medium – Past reference date (30 September 2025) as of January 2026 means non-reporting firms risk immediate FGDL non-compliance, fines, or supervisory action from CSSF, but this is a routine quarterly survey (see related Circular CSSF-CPDI 25/49 for December 2025). Matters for prudential r
Bank
Press release 25/16
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Press release 25/15
Bank
Single Resolution Fund – Information request by the Single Resolution Board for the calculation of the 2026 contribution according to Articles 4 and 14 of Commission Delegated Regulation (EU) 2015/63
Circular CSSF-CODERES 25/21, issued by the CSSF on 29 September 2025, mandates Luxembourg credit institutions to submit specific data via XBRL-formatted Data Reporting Forms (DRFs) to enable the Single Resolution Board (SRB) to calculate 2026 ex-ante contributions to the Single Resolution Fund (SRF) under Articles 4 and 14 of Commission Delegated Regulation (EU) 2015/63. This matters because non-compliance risks SRB using estimates, applying the highest risk multiplier, or penalties, ensuring the financial sector funds resolution costs without taxpayer burden.
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What Changed
Introduces data collection for 2026 SRF contributions, conditional on SRB verifying SRF funds fall below 1% of covered deposits in the Banking Union by early 2026.
Mandates XBRL submission of DRFs (except restatements up to 2022 in Excel); provides templates in Annexes 3a, 4, 5 (User Guide), and 7a/7b for additional assurances.
Additional assurance requirements (e.g., auditor reports or Agreed-Upon Procedures - AUP) apply conditionally to ECB-supervised institutions unless under lump-sum payment
What You Need To Do
- Download and complete DRF using Annexes (e
- For ECB-supervised institutions
- Align internal systems with CSSF templates early; validate data to avoid SRB assumptions under Article 17(1) DR
- Review Annex 1 (SRB kick-off letter), Annex 4 (2026 Guidance), and Annex 6 (ECB list)
Key Dates
30 November 2025 - SRB decision deadline on whether to calculate/collect 2026 SRF contributions based on DRFs (triggers full additional assurance application). DEADLINE
15 January 2026 - ECB-supervised institutions submit AUP or auditor reports on restatements to CSSF resolution department.
16 January 2026, 24:00 CET - All institutions submit completed DRF in XBRL to CSSF; late/incomplete submissions lead to SRB estimates or highest risk multiplier.
Compliance Impact
Urgency: High - The 16 January 2026 deadline is imminent (today is 25 January 2026), risking immediate SRB penalties like estimates or maximum risk multipliers if submissions are missed/inaccurate; affects capital planning as contributions directly impact prudential positions.
Bank
Press release 25/14
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Adoption of the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures (sanctions)
Circular CSSF 25/896 adopts the EBA Guidelines EBA/GL/2024/14 and EBA/GL/2024/15, mandating Luxembourg financial institutions to establish robust internal policies, procedures, and controls for complying with EU and national restrictive measures (sanctions). This matters because it sets binding EU-wide standards to prevent sanctions violations and circumvention, with absolute obligations for immediate asset freezing and reporting, amid escalating geopolitical tensions.
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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 for violations and circumvention.
Management body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and report deficiencies.
Screening and monitoring requirements: Maint
What You Need To Do
- 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
- 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
Compliance Impact
Urgency: High – With less than 12 months until the 30 December 2025 deadline (as of January 2026), firms face binding requirements for absolute compliance, including personal accountability for management bodies; non-compliance risks enforcement by CSSF, reputational damage, and fines amid frequent
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