🇱🇺 CSSF Enforcement medium

Administrative sanction of 12 January 2026

Published 12 January 2026 | Luxembourg

AI Analysis

Executive Summary

The CSSF imposed a €10,000 administrative fine on BigRep SE on 12 January 2026 for failing to publish its half-yearly financial report as of 30 June 2025, as required under Article 4 of Luxembourg's Transparency Law of 11 January 2008 (as amended). This enforcement action underscores the CSSF's rigorous supervision of periodic disclosure obligations for issuers with Luxembourg as their home Member State, serving as a reminder of the consequences for non-compliance with transparency requirements. Compliance professionals should note this as evidence of ongoing CSSF scrutiny on timely reporting, with potential fines scaled based on circumstances per Article 26a. #

What Changed

This is not a regulatory change or new requirement but an enforcement of existing obligations under the Transparency Law of 11 January 2008 (as amended), specifically Article 4, which mandates issuers to publish half-yearly financial reports, including effective dissemination, storage on the Officially Appointed Mechanism (OAM), and filing with the CSSF. No new rules are introduced; the sanction reinforces the unchanged deadlines and processes for periodic information publication, with the CSSF acting under Article 25(2) as the competent authority. The fine level was determined considering relevant circumstances under Article 26a, and publication follows Article 26b(1). #

What You Need To Do

All affected parties
BigRep SE specifically
wide actions are mandated beyond general adherence, but proactive audits are advisable given CSSF's supervisory focus

Key Dates

30 June 2025 - Period-end date for the required half-yearly financial report that BigRep SE failed to publish. DEADLINE

12 January 2026 - Date of administrative sanction imposition by CSSF and publication of the decision.

Within 3 months of 12 January 2026 (i.e., by 12 April 2026) - Deadline for BigRep SE to lodge a court action with the Tribunal administratif against the sanction, per Article 27 of the Transparency Law. DEADLINE

Compliance Impact

Urgency: Medium – This matters as a specific enforcement example in CSSF's ongoing verification of periodic information publication, signaling heightened scrutiny rather than a systemic shift. While the €10,000 fine is modest, it demonstrates fines for even isolated breaches (scaled per Article 26a), potentially escalating for repeats; firms should prioritize reporting calendars to avoid reputatio

Who is Affected

Issuers of securitiesPublicly traded companiesyearly financial reports, including effective dissemination, OAM storage, and CSSF filing.Compliance officers and governance teams