What does CSSF's "Circular CSSF-CPDI 25/48 (track changes)" change?

- 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 uniform per compartment but institution-specific via risk and deposit changes; handles mergers and limits added amounts to cover gaps (Γ_λ). - Repeals Prior Circulars: Repeals CSSF-CPDI 23/34 (4 June 2020) and CSSF-CPDI 20/21 (as amended), replacing the 2020-reviewed method.

What should firms consider doing?

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 Conduct gap analysis against repealed circulars (20/21, 23/34); update policies for mergers, deposit changes, and gap fillings (Γ_λ).

🇱🇺 CSSF Guidance high

Circular CSSF-CPDI 25/48 (track changes)

Published 13 November 2025 | Luxembourg

AI Analysis

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.

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).

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.

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

Primary: All FGDL member institutions, i.e., Luxembourg credit institutions (banks) subject to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and certain investment firms.
Secondary: CSSF-supervised entities with covered deposits; FGDL for invoicing and collection.

Prior FGDL Methodologies
cssf-cpdi-20-21/ 2
EBA Guidelines Integration
content/uploads/cssf24_868eng.pdf 15
Recent CSSF Developments
cssf-cpdi-25-49/ ; https

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

What the CSSF said

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

Published by CSSF . Read the full notice at the source for the authoritative text.

Sectors

Banking & Credit

Topics

Prudential / Capital Requirements

Relevant Firm Types

Bank

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