Circular CSSF 22/821 (as amended by Circulars CSSF 24/865, CSSF 23/845 and CSSF 25/897) (Updated)
Executive Summary
**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 Protection: A dedicated auditor assessment on safeguarding of client financial instruments Scope of SAQ Coverage: The questionnaire addresses prudential supervision matters including governance, risk management, capital adequacy, liquidity, and anti-money laundering/counter-terrorist financi
What You Need To Do
- *For Credit Institutions
- *Establish SAQ Governance
- *Data Preparation
- *Digital System Access
- *Module Completion
- *Timeline Compliance
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
Summary
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)