CSSF News

Key dates

2026-06-08

CSSF consultation on proposed guidance was published.

2026-08-03 Deadline

Deadline for stakeholder responses to the consultation.

2026-10-30

CSSF published the final guidance and confirmed a three-month implementation period.

2027-01-30 Deadline

End of the three-month implementation period calculated from publication of the final guidance; affected firms should have implemented the guidance by this date.

Suggested considerations

• Firms should identify each affected MMF's classification under Regulation (EU) 2017/1131 and map its current WLA and DLA monitoring against both the binding MMFR minima and the applicable 20% or 40% market-resilience benchmark.
• Compliance and risk teams may wish to update liquidity-risk policies, escalation thresholds, governance papers and management information to address enhanced vigilance when WLA approaches or falls below the benchmark.
• Managers should incorporate the 20% VNAV and 40% PD CNAV/LVNAV levels into Article 28 MMFR stress-testing methodology, scenarios, documentation and vulnerability-remediation processes.
• Firms should establish controls to identify a breach lasting more than 10 business days and to prepare timely CSSF notifications containing the causes, expected duration, justification and relevant Article 28(4) and (5) measures.
• Boards, conducting officers and relevant risk committees may wish to review whether internal decision-making and escalation procedures are sufficiently reinforced for prolonged or substantial deviations.
• Firms should distinguish clearly in investor, regulatory and internal reporting between binding MMFR liquidity minima and the CSSF's supervisory market-resilience benchmarks, since the latter are not new statutory minimum ratios.
• Luxembourg MMF managers should assess operational readiness during the three-month implementation period and retain evidence of implementation, monitoring and supervisory communications.

What changed

The final guidance largely confirms the consultation proposal and introduces only slight clarifications. MMF managers should incorporate market-resilience WLA levels of 20% for VNAV MMFs and 40% for PD CNAV and LVNAV MMFs into liquidity-risk management and Article 28 MMFR stress-testing processes. These levels operate as supervisory and risk-management benchmarks above the MMFR minimum WLA ratios of 15% for VNAV MMFs and 30% for PD CNAV and LVNAV MMFs; the minimum daily liquid asset ratios remain 7.5% for VNAV MMFs and 10% for PD CNAV and LVNAV MMFs.

Key dates

2026-12-07 Deadline

First phased requirements apply to investment firms and their clients for allocations and confirmations, including electronic, standardised, international-standard and machine-readable communications except during temporary technical disruptions.

2027-07-01 Deadline

Second phased implementation deadline under the amended settlement-discipline framework.

2027-10-11 Deadline

EU securities markets move from the standard T+2 settlement cycle to T+1; the final phased settlement-discipline requirements apply.

Suggested considerations

• Firms should map every allocation, confirmation, matching and settlement-instruction process affected by the amended settlement-discipline RTS and identify manual, non-standardised or non-machine-readable steps.
• Compliance teams may wish to confirm that electronic, standardised communication channels and international messaging standards are available to the firm and its professional clients before 7 December 2026.
• Firms should consider implementing trade-date controls, internal cut-offs, automated alerts, escalation procedures and exception reporting to identify transactions at risk of missing the applicable allocation and confirmation deadline.
• Investment firms may wish to review client onboarding and contractual documentation to ensure that professional clients provide complete settlement details and use compatible communication channels and formats.
• Operations and technology teams should test end-to-end connectivity, message formats, reference data, settlement instructions, matching, foreign-exchange funding, securities lending, collateral and asset-servicing workflows across the entire trading and settlement ecosystem.
• Firms should assess readiness not only within their own organisation but also across brokers, custodians, clients, fund administrators, CSDs, settlement agents and other outsourced providers.
• Firms should establish a phased implementation plan covering the 7 December 2026, 1 July 2027 and 11 October 2027 milestones, with evidence of testing, issue remediation and management oversight.
• Compliance teams may wish to monitor further ESMA and CSSF supervisory communications because ESMA and national competent authorities have indicated that they will monitor compliance with the new obligations.

What changed

Amended settlement-discipline regulatory technical standards under Commission Delegated Regulation (EU) 2018/1229 introduce phased requirements supporting the EU T+1 transition. From 7 December 2026, investment firms and their clients must use electronic, standardised communication channels and international messaging standards for allocations and confirmations, with machine-readable communication required except during temporary technical disruptions.

Key dates

2026-10-21

CSSF published the communiqué warning about CVE-2026-109618 and CVE-2026-109619; PHP also released security updates addressing the vulnerabilities on this date.

Suggested considerations

• Firms should consider urgently inventorying internet-facing and internally accessible services that run PHP, including PHP embedded in outsourced, cloud-hosted and vendor-managed applications.
• Technology and security teams may wish to determine the installed PHP branch and apply the relevant fixed release, including PHP 8.5.12, 8.4.27, 8.3.36 or 8.2.35 where applicable, after validating compatibility and deployment integrity.
• Where immediate patching is not feasible, firms should consider isolating or taking affected internet-facing services offline, placing them behind network-layer authentication or equivalent compensating controls, and restricting PHP execution to required functions.
• Security teams may wish to review web-server, PHP, application, endpoint and identity logs for exploitation indicators, unusual child processes, unexpected outbound connections, persistence and activity associated with unauthenticated requests.
• Firms should consider assessing whether any unauthorised remote code execution, suspected compromise or material service disruption meets the applicable major ICT-related incident criteria and documenting the classification decision.
• DORA entities should consider preparing the notification required under Circular CSSF 25/893 and the applicable DORA implementing rules if the incident is classified as major; the initial notification is generally due within four hours of classification and no later than 24 hours after awareness, followed by an intermediate report within 72 hours and a final report within one month.
• Entities subject to CSSF Circular 24/847 should consider following that circular's notification process for a major ICT-related incident and confirming whether any parallel obligations arise under applicable NIS or sectoral requirements.
• Compliance teams may wish to retain evidence of the affected-asset inventory, patch or mitigation decisions, threat monitoring, incident assessment and communications with relevant ICT third-party providers.

What changed

The publication does not introduce a new standalone rule or compliance deadline; it provides an urgent supervisory warning and links the risk to existing ICT incident-reporting obligations. Until the affected versions were officially confirmed, the CSSF's stated position was that all PHP-powered services should be treated as potentially exposed. Independent security analysis reported that PHP released fixes on 21 October 2026 in versions 8.5.12, 8.4.27, 8.3.36 and 8.2.35, with both vulnerabilities rated CVSS 4.0 at 9.2 and capable of execution under the web-worker account.

Key dates

2026-02-09

AMLA opened the public consultation on the draft RTS concerning business relationships, occasional and linked transactions, lower thresholds, and customer due diligence.

2026-04-16

AMLA opened the public consultation on the draft RTS concerning group-wide requirements and additional measures for subsidiaries and branches in third countries.

2026-05-08

Public consultation closed for the business-relationship, transaction and customer-due-diligence draft RTS.

2026-06-15

Public consultation closed for the group-wide arrangements and third-country legal-impediment draft RTS.

2026-10-01

AMLA announced that it had finalised the three draft RTS and submitted them to the European Commission for formal adoption.

2026-10-07

CSSF published its communiqué drawing Luxembourg professionals’ attention to the draft RTS and recommending preparatory gap analysis and control work.

Suggested considerations

• Compliance teams may wish to complete a gap analysis against the AMLA final reports, particularly for customer and beneficial-owner information, verification sources, electronic identification, non-face-to-face onboarding and PEP screening.
• Firms should consider mapping current customer journeys and transaction-monitoring logic to the proposed distinction between business relationships, occasional transactions and linked transactions.
• Firms may wish to identify products, sectors and transaction types that could be affected by lower CDD thresholds for higher-risk activities, while avoiding reliance on unfinalised monetary thresholds.
• Financial groups should consider reviewing group-wide AML/CFT governance, risk assessments, policies, internal controls, training and secure information-sharing arrangements, including structures involving common ownership, management, compliance control, networks or partnerships.
• Groups with branches or subsidiaries in third countries should consider inventorying legal impediments to applying EU AMLR and group policies and preparing escalation, risk-mitigation and supervisory-response procedures.
• IT and operations teams may wish to assess changes needed for customer-data fields, linked-transaction detection, identity-verification evidence, electronic identification and intra-group information exchange.
• Firms should monitor the European Commission’s adoption process and the Official Journal publication because the final text, effective date and any amendments remain unknown; preparatory work should be calibrated to the proposed six-month transition period rather than treated as a current binding deadline.

What changed

The draft RTS under Article 19(9) of Regulation (EU) 2024/1624 would establish criteria for distinguishing business relationships, occasional transactions and linked transactions, and would identify high-risk obliged entities, sectors or transactions for which lower CDD thresholds should apply. The draft RTS under Article 28(1) would specify information and verification requirements for standard, simplified and enhanced CDD, including reliable and independent verification sources, electronic identification means, qualified trust services, non-face-to-face verification, and relevant treatment...

Key dates

2025-01-17

DORA began applying to in-scope financial entities supervised by the CSSF.

2025-12-17

The European Commission confirmed through DORA Q&A 102 that DORA applies to qualifying third-country branches in an EU Member State.

2026-06-30 Deadline

CSSF’s extended best-efforts deadline for the first register-of-information submission by third-country branches of credit institutions headquartered in a third country.

2026-08-27

Circular CSSF 26/915 was published and took effect immediately; the listed CSSF circulars were amended to include or remove qualifying third-country branches as applicable.

2027-03-31 Deadline

Target date identified by CSSF for the required-quality register-of-information submission by third-country branches of credit institutions headquartered in a third country.

2027-01-11

Relevant CRD VI third-country-branch provisions are scheduled to take effect, subject to national transposition and applicable transitional rules.

Suggested considerations

• Firms should map each Luxembourg third-country branch against the counterfactual test in Circular 26/915: whether the head-office undertaking would qualify under Article 2(1)(a) to (t) of DORA if established in the relevant third country.
• Affected branches should update their regulatory-perimeter inventories, governance documents, ICT-risk policies, outsourcing inventories, incident-classification procedures and DORA control testing to reflect immediate inclusion in the DORA-specific CSSF circulars.
• Compliance teams may wish to separate non-ICT outsourcing, which remains subject to Part I of Circular CSSF 22/806, from ICT outsourcing, which is governed by DORA and Circular CSSF 25/882 rather than the legacy Part II framework.
• Affected entities should validate their register-of-information process under DORA and Circular CSSF 25/882, including branch-level data, ICT third-party contracts, intra-group arrangements and submission ownership. The 30 June 2026 best-efforts deadline for third-country branches of credit institutions has passed, and firms should prepare for the 31 March 2027 collection and any CSSF remediation requests.
• Incident-response teams should test access to the CSSF eDesk procedure and S3 API and document an escalation process for emailing [email protected] when technical impossibility prevents electronic submission.
• Firms should assess whether they qualify for the microenterprise exclusion in Circular CSSF 25/892; the exclusion applies to entities employing fewer than 10 persons with annual turnover and/or annual balance-sheet total not exceeding EUR 2 million, subject to the DORA definition and exclusions for specified market infrastructures.
• Third-country banking groups should coordinate DORA implementation with the CRD VI third-country-branch analysis, including the 11 January 2027 effective date for relevant CRD VI provisions, rather than assuming that the two regimes have identical scope or timing.

What changed

Qualifying third-country branches are added to the scope of Circulars CSSF 25/882, 25/892 and 25/893, covering DORA ICT third-party-service information and reporting, estimation of aggregated annual costs and losses from major ICT-related incidents under Article 11(11) of DORA and the Joint ESA Guidelines JC/GL/2024/34, and reporting of major ICT-related incidents and significant cyber threats.