Circular CSSF-CODERES 25/21
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-
- References SRB's 2026 kick-off letter (Annex 1) and ECB-supervised list (Annex 6 as of 24 September 2025).
Suggested Considerations
- Download and complete DRF using Annexes (e.g., Annex 3a PDF, Annex 5 User Guide v1.4); submit in XBRL format by deadline.
- For ECB-supervised institutions: Provide additional assurances per Annex 7a/7b if SRB proceeds with collections; prepare restatement AUPs with auditor exceptions where applicable.
- 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
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
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
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