Circular CSSF 26/913

Key dates

22 June 2026

- Circular CSSF 26/913 is published and the CSSF confirms application of EBA/GL/2026/01

TBD (effective date not stated in the publication)

- Firms should apply the CSSF’s expectations from the date the circular becomes applicable, if that date is specified in the full circular text or accompanying CSSF notice

TBD (implementation date not stated in the publication)

- Affected firms should complete internal perimeter reviews and any resulting governance or reporting updates by the first supervisory reporting cycle after application

Suggested considerations

• Review all group entities and business lines to identify activities that may fall within the definition of an ancillary services undertaking under Article 4(1)(18) CRR.
• Document a formal assessment methodology for classifying activities against the EBA/GL/2026/01 criteria.
• Reconfirm the prudential consolidation perimeter and ensure all ancillary service entities are correctly included or excluded, with the reasoning retained for supervisory review.
• Update legal entity inventories, regulatory mapping, and governance documents so they align with the CSSF’s adopted EBA framework.
• Test whether existing internal reporting, risk management, and control frameworks capture any newly identified ancillary services undertakings.
• Brief board and senior management on the perimeter implications of the CSSF circular and assign ownership for ongoing classification decisions.

What changed

• - The CSSF has formally applied the EBA Guidelines on ancillary services undertakings specified in EBA/GL/2026/01 for identifying activities under Article 4(1)(18) of Regulation (EU) No 575/2013.
• Firms must assess whether a non-bank activity or group entity qualifies as an ancillary services undertaking under the EBA criteria, rather than relying on internal labels or informal business descriptions.
• The regulatory perimeter analysis now needs to consider whether relevant activities are performed within a banking group in a way that affects prudential consolidation and supervisory treatment.
• Institutions should expect the CSSF to use the EBA framework as the benchmark for determining whether an activity is sufficiently connected to banking support functions to fall within the ancillary services concept.
• Compliance evidence will need to show a documented, reproducible assessment of each potentially relevant activity against the EBA identification criteria.

Who is affected

• Luxembourg credit institutions
• Banking groups
• Less significant institutions
• bank service operations.
• Group compliance, prudential, and legal teams
• Outsourced service or intra-group service entities
• Holding structures

Related regulations

• based compliance decisions.