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 cover
- 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 uniform per compartment but institution-specific via risk and deposit changes; handles merge
- Repeals Prior Circulars: Repeals CSSF-CPDI 23/34 (4 June 2020) and CSSF-CPDI 20/21 (as amended), replacing the 2020-reviewed method.
Suggested Considerations
- 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.g., ROA, LCR, NSFR, NPL) against adjusted sliding scales; ensure alignment with EBA Guidelines for simplicity and resource efficiency.
- Prepare for FGDL invoices reflecting compartment-specific rates; monitor covered deposits for surveys (e.g., per Circular 25/49).
- Conduct gap analysis against repealed circulars (20/21, 23/34); update policies for mergers, deposit changes, and gap fillings (Γ_λ).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
References
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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