Circular CSSF 22/821 (as amended by Circulars CSSF 24/865, CSSF 23/845 and CSSF 25/897) (Updated)
AI Analysis
**Circular CSSF 22/821** (as amended) fundamentally restructures how Luxembourg credit institutions report to the Commission de Surveillance du Secteur Financier (CSSF) by replacing the traditional Long Form Report with a digital **self-assessment questionnaire (SAQ)**, complemented by auditor-prepared reports. This shift represents a significant operational change that requires institutions to directly participate in prudential self-assessment while maintaining robust external audit oversight, making it essential for compliance and operational teams to understand new submission requirements and digital workflows.
Key dates
- 25 October 2022
- - Circular CSSF 22/821 issued
- 23 December 2022
- - Initial publication date (updated 15 November 2023)
- 31 December 2022
- - Circular enters into application
- Three months before financial year closure
- - SAQ becomes accessible through CSSF digital solution
- Three months after financial year closure Deadline
- - Deadline for SAQ submission to CSSF
- Five months after financial year closure Deadline
- - Deadline for REA reports submission
Suggested considerations
- *For Credit Institutions:
- *Establish SAQ Governance: Designate authorized management responsible for reviewing and electronically signing the SAQ before submission; ensure accuracy and true-and-fair representation of information
- *Data Preparation: Align SAQ responses with prudential reporting figures (FINREP/COREP/LAREX) under IFRS as of financial year closure
- *Digital System Access: Obtain access credentials to the CSSF digital solution and familiarize compliance teams with the platform interface and submission workflow
- *Module Completion: Complete all applicable SAQ modules as configured in the CSSF digital solution; note that module applicability and exemptions are institution-specific and recorded directly in the system
- *Timeline Compliance: Submit SAQ within three months of financial year closure; coordinate with external auditors to ensure REA reports are submitted within five months
What changed
- The circular introduces a three-component reporting framework that fundamentally alters the compliance landscape:
- Self-Assessment Questionnaire (SAQ): A digital, annually-completed questionnaire that institutions must prepare directly, covering domains within CSSF and ECB prudential supervision competence
- Agreed Upon Procedures (AUP) Reports: Reports prepared by approved statutory auditors (réviseurs d'entreprises agréés) on specific compliance areas
- Separate REA Report on Financial Instruments Protection: A dedicated auditor assessment on safeguarding of client financial instruments Scope of SAQ Coverage: The questionnaire addresses prudential supervision matters including governance, risk mana
Compliance impact
Urgency: HIGH
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
What the CSSF said
Long Form ReportPractical rules concerning the self-assessment questionnaire to be submitted by institutionsMission and related reports of the statutory auditors (réviseurs d’entreprises agréés)
Published by CSSF . Read the full notice at the source for the authoritative text.