🇱🇺 CSSF Guidance high

Circular CSSF-CODERES 25/21

Published 29 September 2025 | Luxembourg

AI Analysis

Executive Summary

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. #

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; restatements require AUP by 15 January 2026 with exceptions for prior auditor-identified errors. - References SRB's 2026 kick-off letter (Annex 1) and ECB-supervised list (Annex 6 as of 24 September 2025). #

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.

Who is Affected

All Luxembourg credit institutions subject to Regulation (EU) No 806/2014 (Single Resolution Mechanism - SRMR).Specifically, institutions under direct ECB supervision (listed in Annex 6) face enhanced additional assurance obligations, excluding those on lump-sum payments (Article 10(1)-(6) DR 2015/63) or alternative contributions (Article 10(7)).Investment firms under CSSF supervision may also be included per related frameworks.

References

Summary

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