Circular CSSF-CPDI 25/47
Executive Summary
Circular CSSF-CPDI 25/47 mandates a regular survey by Luxembourg credit institutions on the amount of covered deposits as of **30 September 2025**, focusing on eligible and covered deposits under the Law of 18 December 2015 on deposit guarantee schemes. It matters because it ensures accurate reporting to the Conseil de protection des déposants et des investisseurs (CPDI) for FGDL (Fonds de garantie des dépôts Luxembourg) compliance, with detailed field-by-field instructions for complex accounts like omnibus and trusts. #
What Changed
This circular updates prior guidance (notably CSSF-CPDI 16/02 as amended by CSSF-CPDI 23/35) by specifying the survey reference date of 30 September 2025 and providing granular reporting fields for eligible deposits (e.g., exclusions for financial institution-like structures and life insurance products), covered deposits capped at €100,000 per person, and breakdowns by natural/legal persons, including shares in omnibus accounts, fiduciaries, trusts, sub-accounts, and segregated accounts. Key fields include 0100 (total deposits), 0201 (total eligible deposits post-exclusions), 0300 (total covered deposits), and sub-fields like 0210-0225 for apportionment by holder status and balance thresholds (≤/> €100,000). It emphasizes reasonable measures to identify absolutely entitled persons in non-s
What You Need To Do
- For omnibus/trust accounts, obtain and report shares of identifiable entitled persons, apportion by legal status of holder, and ensure fields like 0226 and 0255 reconcile
- Designated management reviews/approves data; transmit accurately to CSSF/CPDI, respecting prior circulars (e
- Exclude non-creditor accounts or those assimilated to financial institutions/life insurance
Key Dates
Compliance Impact
Urgency: Medium – Past reference date (30 September 2025) as of January 2026 means non-reporting firms risk immediate FGDL non-compliance, fines, or supervisory action from CSSF, but this is a routine quarterly survey (see related Circular CSSF-CPDI 25/49 for December 2025). Matters for prudential reporting accuracy, especially amid EU deposit guarantee harmonization.
Who is Affected
Summary
Survey on the amount of covered deposits held on 30 September 2025