Circular CSSF-CPDI 25/48 (track changes)
Executive Summary
Circular CSSF-CPDI 25/48, published on 13 November 2025, updates the methodology for calculating ex-ante contributions to the Fonds de garantie des dépôts Luxembourg (FGDL), Luxembourg's deposit guarantee scheme, by aligning risk adjustments with EBA Guidelines and introducing a zero floor for certain calculation components. This matters for Luxembourg credit institutions as it refines risk-sensitive contributions to meet DGSD target levels for two compartments (0.8% and an additional 0.8% of covered deposits), ensuring financial stability while promoting supervisory convergence across the EU. #
What Changed
- Risk Adjustment Updates (Annex 2): Increases weight of 'Return on assets' (ROA) risk indicator from 7.5% to 10%; decreases 'Deposit-size Risk' from 15% to 12.5%; adjusts sliding scale bounds for indicators like leverage ratio (3%-9%), capital coverage ratio (100%-200%), LCR/NSFR (100%-200%), NPL ratio (0%-3%), and others per Table 2, aligning with minimum EBA Guidelines weights totaling 75% plus national flexibility. - Formula Component Floor (Annex 1): Introduces a zero floor for Component 1 (max(0, A_{j,k})), preventing negative values from offsetting Component 2; retains both components but ensures no cross-compensation. - Contribution Calculation Refinements: Annual contributions per compartment use updated formulas (e.g., formula (1) with max operator); contribution rates are unifor
What You Need To Do
- Review and update internal systems/models for contribution calculations to incorporate new risk weights, bounds (Table 2), zero floor for Component 1, and revised formulas in Annexes 1-2
- Validate data reporting for risk indicators (e
- Prepare for FGDL invoices reflecting compartment-specific rates; monitor covered deposits for surveys (e
- Conduct gap analysis against repealed circulars (20/21, 23/34); update policies for mergers, deposit changes, and gap fillings (Γ_λ)
Compliance Impact
Urgency: High – Institutions must promptly recalibrate risk models ahead of 2026 contributions to avoid miscalculations, penalties, or underfunding risks, as this directly impacts prudential contributions amid ongoing DGSD buildup to 2026; non-alignment with EBA could trigger CSSF scrutiny. Failure to adapt may increase costs for riskier profiles, emphasizing the shift to greater risk sensitivity.
Who is Affected
Summary
Fonds de garantie des dépôts Luxembourg (FGDL) – Method for calculating the ex-ante contributions pursuant to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and of certain investment firms