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Circular CSSF 25/903

AI Analysis

Executive Summary

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. #

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 and Separate Report: Establishes detailed rules for auditors to issue an annual management letter (addressing findings, recommendations, and remediation) and a separate report for CSSF submission, with templates and validation criteria to ensure uniformity and reliability. - Enhanced Documenta

What You Need To Do

  • *Review and Update Processes
  • *Engage/Confirm Auditors
  • *Implement Templates and Testing
  • *Training and Governance
  • *Submit on Time
  • *Monitor CSSF Updates

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, potentially increasing costs (e.g., auditor fees) while reducing reporting errors—critical for smaller supp

Who is Affected

Primaryoffice support to authorized PFS without direct client-facing activities).SecondaryOthersclient-facing support providers licensed as PFS).

Summary

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.

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