CSSF Consultations

What Changed

• - ESMA is consulting on technical advice to the European Commission specifically targeting selected KPIs under the Taxonomy Disclosures Delegated Act (Article 8 of the Taxonomy Regulation), including...
• The stated policy objective is simplification of the EU Taxonomy disclosure framework while preserving decision‑useful information for investors and supervisors.
• ESMA aims to reduce reporting burdens for market participants, notably corporates and financial institutions subject to Taxonomy Article 8 disclosures.
• The consultation covers selected KPIs under the Taxonomy Disclosures Delegated Act, with the European Commission having requested focused advice on: OpEx KPI of non‑financial firms; Commissions and...
• ESMA is proposing more pragmatic approaches to group‑level reporting for mixed groups, including reporting at parent‑undertaking level to reduce complexity for conglomerates.

Suggested Considerations

• Conduct an internal impact assessment of current Taxonomy Article 8 KPI calculation and reporting processes, focusing on OpEx, Commissions and Fees, Trading Book, and Underwriting KPIs, to identify pain points and simplification priorities.
• Prepare and submit a response to ESMA’s consultation by 12 August 2026, either directly or via industry associations, articulating specific operational, data, and system challenges and concrete proposals for simplification.
• Register for and attend ESMA’s public hearing on 22 July 2026 to understand the detailed proposals, ask clarifying questions, and align internal positions ahead of submission.
• Coordinate with regulatory affairs, sustainability, risk, and finance functions to develop a unified institutional position on the desired design of revised KPIs and group‑level reporting under the Taxonomy Disclosures Delegated Act.
• Map dependencies between Taxonomy Article 8 data and other ESG reporting (including SFDR product disclosures and CSRD/ESRS reporting) to anticipate how changes to KPIs may affect cross‑framework consistency and data architecture.

Key Dates

References

• [1] onestopesg.com/esg-news/esma-eu-taxonomy-disclosure-simpl...
• [2] sustainablefutures.linklaters.com/post/102mmq2/eu-esas-to...
• [3] linkedin.com/posts/martin-w-schoenberger_esma-consults-on...
• [4] mayerbrown.com/en/insights/publications/2024/08/the-esma-...
• [5] finance.ec.europa.eu/sustainable-finance/disclosures/sust...
• [6] facebook.com/spectreco.0/posts/esma-recommends-enhancemen...
• [7] esma.europa.eu/esmas-activities/sustainable-finance
• [8] eurosif.org/policies/eu-taxonomy-sustainable-investments/

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,...

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).

Key Dates

References

• [1] mayerbrown.com/en/insights/publications/2025/08/fatf-revi...
• [2] moodys.com/web/en/us/kyc/resources/insights/fatf-recommen...
• [3] innreg.com/blog/fatf-travel-rule-crypto-fintech-complianc...
• [4] vaspnet.com/articles/how-the-eus-travel-rule-goes-above-a...
• [5] sumsub.com/blog/what-is-the-fatf-travel-rule/

What Changed

• - The CSSF has created a standardised “Application form for authorisation of a UCITS domestic merger” specifically for merger authorisation requests where both merging and receiving UCITS are...
• The CSSF has created a standardised “Application form for authorisation of a UCITS outbound cross‑border merger” for mergers where the merging UCITS is Luxembourg‑authorised and the receiving UCITS...
• Use of the two new forms is mandatory for all new merger authorisation applications submitted to the CSSF from 19 June 2026 onwards; legacy formats (ad‑hoc letters or bespoke templates) may no longer...
• Each application form must be “duly completed” and accompanied by all documents required under the applicable UCITS merger regulations, including the common draft terms of merger, updated prospectus...
• The CSSF has specified a centralised submission channel for these applications: completed forms and supporting documentation must be sent to amendments.uci@cssf.lu, aligning merger filings with the...

Suggested Considerations

• Identify all current and planned UCITS domestic and outbound cross‑border merger projects and determine which will have CSSF authorisation requests submitted on or after 19 June 2026 so that the new forms are used.
• Download and review in detail the “Application form for authorisation of a UCITS domestic merger” and “Application form for authorisation of a UCITS outbound cross‑border merger” and map each field of the forms to existing internal data sources and documents.
• Update internal UCITS merger procedures and checklists to replace any existing CSSF filing templates with the new standardised forms and to include the requirement that all merger authorisation applications are submitted to amendments.uci@cssf.lu.
• Train legal, product, operations and compliance staff involved in UCITS mergers on how to complete the new forms accurately, including coordination of information across the prospectus, KIIDs/KIDs, common draft merger terms, depositary statements and shareholder communications.
• Review and, where necessary, update board and governance templates (board minutes, resolutions approving merger terms) to ensure they produce all information that the new forms require to be confirmed or attached.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/Standardised-Model-Articles-of...
• [2] cliffordchance.com/content/dam/cliffordchance/briefings/2...
• [3] cssf.lu/wp-content/uploads/L_171210_UCI.pdf
• [4] cssf.lu/wp-content/uploads/RCSSF_No10-05eng.pdf
• [5] maples.com/knowledge/cssf-simplified-procedure-for-creati...
• [6] vaneck.com/ucits/common-draft-terms-of-the-merger.pdf
• [7] cssf.lu/en/ucits-marketing/
• [8] mandg.com/dam/investments/common/shared/en/documents/fund...

What Changed

• Given the consultation nature and the absence of a published consultation text in the extract, the following points reflect what compliance teams should reasonably anticipate and prepare for, based...
• The CSSF is consulting on formal guidance that will specify how MMFs domiciled in Luxembourg should determine, monitor, and maintain weekly liquid asset levels under the EU Money Market Funds...
• The guidance is expected to operationalise the MMFR WLA requirements (for example, minimum weekly liquidity levels and interaction with redemption activity) by setting out supervisory expectations on...
• The consultation will likely address the interaction between WLA levels and the use of liquidity management tools (such as gates, fees, or suspensions), including expectations on when and how...
• The CSSF is expected to clarify how MMFs should incorporate WLA targets and thresholds into their internal risk management policies, including stress-testing assumptions, early warning indicators,...

Suggested Considerations

• Review the CSSF consultation paper in full as soon as it is available and identify all proposed expectations relating to weekly liquid asset levels, monitoring, and escalation.
• Map the proposed CSSF guidance against current MMF liquidity policies, prospectus disclosures, and internal procedures to identify gaps and potential areas needing enhancement.
• Assess whether existing MMF weekly liquidity monitoring tools, dashboards, and reporting are sufficient to meet anticipated CSSF expectations on frequency, granularity, and early warning indicators.
• Evaluate the current escalation framework for declining WLA levels, including board and senior management involvement, and update governance documentation to align with the likely CSSF approach to thresholds and decision‑making.
• Review MMF stress‑testing methodologies to ensure that scenarios adequately capture severe but plausible redemption and market stress in relation to WLA levels and that results are integrated into risk appetite and contingency planning.

Key Dates

References

• [1] cssf.lu/en/2020/07/transmission-instructions-for-reportin...
• [2] cssf.lu/en/authorisation-of-a-uci/
• [3] cssf.lu/en/anti-money-laundering-and-countering-the-finan...
• [4] cssf.lu/en/Document/circular-cssf-18-698/
• [5] cssf.lu/en/prospectus/
• [6] cssf.lu/en/file-transport-and-data-protection/
• [7] cssf.lu/en/
• [8] cssf.lu/en/money-market-funds/

What Changed

• - The CSSF publishes a dedicated Feedback Report on the thematic review of valuation frameworks for less liquid and illiquid assets and formally expects IFMs to use it as guidance for implementing...
• All Luxembourg IFMs are required to conduct a benchmarking exercise of their valuation frameworks against the CSSF’s observations and recommendations set out in the new Feedback Report.
• Where gaps or weaknesses are identified through this benchmarking, IFMs are expected to implement corrective measures to strengthen their valuation policies, procedures and lifecycle controls for...
• The thematic review scope formally covers AIFMs of AIFs investing in less liquid and illiquid assets (including private equity, real estate, infrastructure, private debt and fund of funds), and, on...
• The CSSF explicitly links this thematic work to previous supervisory exercises (ESMA CSA on valuation, CSSF self‑assessment questionnaires, and on‑site inspection feedback) and consolidates...

Suggested Considerations

• Perform a structured benchmarking of existing valuation policies, procedures, methodologies and controls against the detailed observations and recommendations in the CSSF Feedback Report on valuation frameworks for less liquid and illiquid assets.
• Document, at IFM and fund level, all identified gaps or weaknesses in the current valuation framework, including for AIFs in illiquid strategies and UCITS Article 41(2) trash ratio positions.
• Develop and approve a remediation plan with clear owners, milestones and target dates to address identified shortcomings in valuation governance, methodologies, model validation, data sources and control processes.
• Review and, where necessary, update valuation policies and procedures to ensure they explicitly cover less liquid and illiquid assets, stressed market conditions, use of external valuers, and documentation standards across the investment lifecycle.
• Enhance valuation governance by clearly defining roles and responsibilities (including segregation from portfolio management where applicable), escalation procedures, and oversight by the board/senior management.

Key Dates

References

• [1] elvingerhoss.lu/publications/cssf-feedback-report-esma-cs...
• [2] ey.com/en_lu/insights/wealth-asset-management/cssf-spotli...
• [3] cssf.lu/en/2023/07/cssf-feedback-report-on-esma-common-su...
• [4] cssf.lu/wp-content/uploads/ESMA_CSA_valuation_CSSF_Feedba...
• [5] esma.europa.eu/sites/default/files/2023-05/ESMA34-45-1802...
• [6] cssf.lu/en/investment-fund-industry-studies/
• [7] iosco.org/library/pubdocs/pdf/IOSCOPD721.pdf
• [8] fsb.org/uploads/P270224.pdf

What Changed

• Based on the prior CSSF feedback on valuation and the indicated thematic focus, compliance teams should expect the following concrete expectations to apply specifically to less liquid and illiquid...
• Investment fund managers must maintain concise, centralised, and comprehensive valuation policies and procedures that explicitly cover all asset types, including less liquid and illiquid instruments,...
• Valuation policies must define and justify the valuation methodologies and models used for less liquid and illiquid assets, including the hierarchy of methods, model selection criteria, and...
• Firms must perform robust model governance for valuation models used on less liquid and illiquid assets, including independent model review (by staff not involved in model development), back‑testing,...
• Valuation frameworks must explicitly address stressed market conditions for illiquid and thinly traded assets, including triggers for stress conditions, alternative valuation methodologies under...

Suggested Considerations

• Conduct a comprehensive gap analysis of existing valuation policies and procedures against the CSSF’s feedback on valuation, with specific attention to less liquid and illiquid assets, and document all identified weaknesses and remediation actions.
• Update and formally approve valuation policies and procedures to clearly define methodologies, model hierarchies, and data source selection for less liquid and illiquid assets, including explicit provisions for stressed market conditions.
• Implement or enhance a formal valuation model governance framework for illiquid asset models, including independent model validation, periodic back‑testing, documentation of assumptions, and at least annual model reviews.
• Review and, where necessary, redesign organisational arrangements to ensure the operational and hierarchical independence of the valuation function from portfolio management, and adjust remuneration policies to avoid performance‑linked incentives for valuation staff.
• Strengthen controls over external pricing providers and external valuers by documenting selection criteria, performing initial and ongoing due diligence, challenging methodologies, and periodically back‑testing third‑party valuations of illiquid assets.

Key Dates

References

• [1] elvingerhoss.lu/publications/cssf-feedback-report-esma-cs...
• [2] ey.com/en_lu/insights/wealth-asset-management/cssf-spotli...
• [3] cssf.lu/en/2026/03/the-cssfs-2026-priorities-for-supervis...
• [4] cssf.lu/en/2023/07/cssf-feedback-report-on-esma-common-su...
• [5] cssf.lu/wp-content/uploads/ESMA_CSA_valuation_CSSF_Feedba...
• [6] esma.europa.eu/sites/default/files/2023-05/ESMA34-45-1802...
• [7] cssf.lu/en/investment-fund-industry-studies/
• [8] fsb.org/uploads/ALFI-1.pdf

What Changed

• - CSSF is requiring market participants to complete the national competent authorities’ T+1 readiness survey by 9 June 2026, with responses visible only to CSSF and ESMA.
• CSSF is strongly encouraging participation in the EU T+1 Industry Committee second readiness survey to support a Union-wide assessment of market preparedness.
• CSSF is flagging that the transition to T+1 settlement on 11 October 2027 under CSDR will require coordinated changes across the trading and post-trading chain.
• CSSF is warning that forthcoming amendments to the RTS on Settlement Discipline are expected to be endorsed by the European Commission and will further define operational requirements for the T+1...
• ESMA’s revised guidelines on standardised procedures and messaging protocols are intended to make post-trade communication faster, clearer, and more consistent across the EU.

Suggested Considerations

• Complete the CSSF T+1 readiness survey before 9 June 2026 and ensure the submission accurately reflects the firm’s current operational readiness.
• Participate in the EU T+1 Industry Committee second readiness survey to demonstrate engagement with the EU-wide readiness process.
• Review the firm’s allocation and confirmation workflows to ensure they can operate within T+1 timeframes.
• Replace any reliance on oral, manual, or non-machine-readable communications with electronic, standardised messaging channels unless a temporary technical disruption justifies an exception.
• Align internal messaging standards with international messaging protocols used for post-trade communication.

Key Dates

References

• [1] fisglobal.com
• [2] nuvei.com
• [3] bankingcircle.com
• [4] fintechweekly.com/fintech-companies/
• [5] ripple.com
• [6] thefopro.com/deal-round-up-family-offices-fund-fintech-pl...
• [7] bis.org/fsi/publ/insights33.pdf
• [8] mercury.com

What Changed

• - The EU settlement cycle for in‑scope financial instruments under CSDR will shorten from T+2 to T+1 with effect from 11 October 2027, materially reducing the time to complete front‑to‑back trade,...
• CSSF has launched a national competent authorities’ T+1 readiness survey and sets a firm completion deadline of 9 June 2026 for Luxembourg market participants, treating it as a critical supervisory...
• In parallel, CSSF strongly encourages Luxembourg firms to complete the EU T+1 Industry Committee (EUIC) second readiness survey to support an EU‑wide view of T+1 readiness and potential systemic...
• ESMA’s final draft amendments to the CSDR RTS on Settlement Discipline will introduce additional operational requirements specifically designed to support T+1 (e.g.
• ESMA has launched a consultation on updated guidelines on standardised procedures and messaging protocols for allocations, confirmations and affirmations, explicitly aimed at facilitating the T+1...

Suggested Considerations

• Identify all group entities and business lines in Luxembourg that are in scope of CSDR T+1 (trading, clearing, settlement, custody, collateral, fund dealing) and formally designate a T+1 programme owner at senior management level.
• Complete the CSSF T+1 national competent authorities’ survey in full and by 9 June 2026, ensuring that responses accurately reflect current readiness, key risks, dependencies on third parties, and planned remediation milestones.
• Arrange for appropriate internal review and sign‑off (e.g. by Compliance and relevant senior management) of the responses to both the CSSF survey and the EUIC second readiness survey before submission.
• Participate in the EU T+1 Industry Committee second readiness survey and ensure the firm’s answers are consistent with the information provided to CSSF and with internal T+1 project documentation.
• Perform a comprehensive T+1 impact assessment of front‑to‑back trade flows, covering trade execution, allocation, confirmation, affirmation, clearing, settlement, collateral movements, cash and liquidity management, and corporate actions.

Key Dates

References

• [1] ey.com/en_lu/insights/wealth-asset-management/luxembourg-...
• [2] cssf.lu/en/2026/06/reminder-of-the-importance-of-particip...
• [3] fca.org.uk/markets/about-t1-settlement
• [4] cssf.lu/en/t1-settlement-preparing-for-the-future-of-euro...
• [5] esma.europa.eu/esmas-activities/markets-and-infrastructur...
• [6] cssf.lu/en/reporting-to-be-submitted-by-ucis/
• [7] kroll.com/en/publications/financial-compliance-regulation...
• [8] icmagroup.org/market-practice-and-regulatory-policy/repo-...

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...

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.

References

• [1] amla.europa.eu/amla-consults-group-wide-requirements-and-...
• [2] amla.europa.eu/events/public-hearing-draft-rts-group-wide...
• [3] fiaumalta.org/news/amla-publishes-final-report-on-draft-r...
• [4] cssf.lu/en/Document/consultation-by-amla-on-the-draft-reg...
• [5] cssf.lu/en/Document/consultation-by-amla-on-the-draft-rts...
• [6] sepblac.es/en/2026/02/18/development_harmonized/
• [7] amla.europa.eu/policy/public-consultations/consultation-d...
• [8] accountancyeurope.eu/publications/7-principles-for-aml-re...

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...

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

Key Dates

References

• [1] amla.europa.eu/events/public-hearing-draft-guidelines-bus...
• [2] amla.europa.eu/amla-consults-group-wide-requirements-and-...
• [3] fincrimecentral.com/amla-risk-assessment-consultation-group/
• [4] amlintelligence.com/2026/04/latest-amla-launches-consulta...
• [5] amla.europa.eu/events/public-hearing-draft-rts-group-wide...
• [6] cssf.lu/wp-content/uploads/MLTF-Sub-sector-Risk-Assessmen...
• [7] cssf.lu/en/Document/consultation-by-amla-on-the-draft-rts...
• [8] cssf.lu/en/anti-money-laundering-and-countering-the-finan...