Circular CSSF 25/902 Repeals the Circular CSSF 19/731 Regarding the Documents to be Submitted on an Annual Basis by Credit Institutions

Luxembourg Financial Regulatory News:

Circular CSSF 25/902 streamlines the annual reporting process for credit institutions by repealing the older Circular CSSF 19/731. While the core obligation to submit key annual documents—such as external audit reports, ICAAP and ILAAP reports, self-assessment questionnaires, and internal control summaries—remains fully intact, the administrative details have been shifted online. The CSSF now maintains the updated lists of required documents, corresponding deadlines, and applicable entity categories directly on its website, introducing an interactive summary table to help institutions route submissions correctly to either the CSSF or the European Central Bank. Finally, the circular mandates that all documents be transmitted electronically via specific channels (eDesk, e-file, or SOFiE) and formatted as searchable PDFs to facilitate regulatory analysis and cross-sectional comparisons.

This circular CSSF 25/902 repeals Circular CSSF 19/731 regarding the documents to be submitted on an annual basis by credit institutions. The obligation for credit institutions to submit a set of documents on an annual basis remains applicable. Going forward, the updated list of documents to be submitted, the categories of entities concerned, the electronic submission channels to be used, and the corresponding deadlines are published on the CSSF’s website in the section Prudential reporting for credit institutions – Documents to be submitted on an annual basis. An interactive summary table allows institutions to determine the documents to be submitted to the CSSF and to the European Central Bank, based on the type of entity, the financial year-end date and the date of the annual general meeting.

According to the information linked from circular CSSF 25/902, An interactive summary table is available here.

The documents concerned may include, but are not limited to, the following:

• the report of the external auditor (statutory auditor’s report, or short form report) on the solo annual accounts and the consolidated annual accounts if applicable, including notably the opinion of the réviseur d’entreprises, annual accounts, relevant explanatory annexes, management report (in accordance with Circular CSSF 22/826, as amended);
• if the accounts are published under Lux-GAAP, a table on the reconciliation between the FINREP prudential reporting and the published annual accounts (in accordance with Circular CSSF 08/340, as amended);
• the proposed distribution of profits (in accordance with Circular CSSF 22/826, as amended);
• the ICAAP report and the consolidated ICAAP report (in accordance with Circular CSSF 07/301, as amended);
• the ILAAP report and the consolidated ILAAP report, where established separately from the ICAAP report (in accordance with Circular CSSF 07/301, as amended);
• the Self-Assessment Questionnaire as part of the revised long form framework (in accordance with Circulars CSSF  22/821, as amended and CSSF 07/325 as amended).
• the summary report established by the internal auditor (in accordance with Circular CSSF 12/552, as amended);
• the summary report established by the compliance officer (in accordance with Circular CSSF 12/552, as amended);
• the summary report established by the risk control function (in accordance with Circular CSSF 12/552, as amended);
• the confirmation by the authorised management of compliance with Circular CSSF 12/552, as amended (central administration, internal governance and risk management), by way of a single written sentence followed by the signatures of all the members of the authorised management¹ (in accordance with Circular CSSF 12/552, as amended);
• the confirmation by the authorised management of compliance with Circular CSSF 13/555 (Single Customer View) by way of a single written sentence followed by the signatures of all the members of the authorised management;
• the management letter, issued by the external auditor and addressed to the management of the credit institution (in accordance with Circular CSSF 22/826, as amended);
• the data collection template on inactive accounts and inactive safe deposit boxes (in accordance with Circular CSSF 22/825);
• the table and summary report relating to the out-of-court resolution of complaints (introduced by Regulation CSSF N° 16-07 of 26 October 2016 and Circular CSSF 17/671, as amended);
• the PSP ICT Assessment (for credit institutions whose business model includes the provision of payment services, in accordance with Circular CSSF 20/750, as amended);
• the report on the protection of financial instruments and funds belonging to clients as part of the revised long form report (in accordance with Circular CSSF 22/821, as amended);
• the AML/CFT report as part of the revised long form report (in accordance with Circular CSSF 22/821, as amended);
• the summary report established by the internal auditor of the branch or the internal audit report of the head office covering, at the level of the branch, the areas for which the CSSF retains an oversight responsibility as host authority³ (in accordance with Circular CSSF 12/552, as amended);
• the summary report established by the compliance officer of the branch or the report of the compliance function of the head office covering, at the level of the branch, the areas for which the CSSF retains an oversight responsibility as host authority (in accordance with Circular CSSF 12/552, as amended);
• the report(s) of the external auditor on the compliance with the rules on the prevention of money laundering and the fight against terrorism (AML/CFT) and on the applicable conduct of business rules when providing investment services/activities as well as ancillary services to clients by the EU-branch (in accordance with Circular CSSF 07/325, as amended);
• any other documents for significant institutions to be submitted to the ECB pursuant to requirements defined by applicable laws, regulations or the ECB itself.

According to the information linked from circular CSSF 25/902, depending on the type of reporting, credit institutions shall transmit the required documents in electronic form via one of the following channels: eDesk, e-file or SOFiE. For the electronic transmission via e-file and SOFiE, the file naming convention as described in Methods of transmitting reports via external channels (Naming convention), point 14, must be complied with.

According to the information linked from circular CSSF 25/902, the documents to be submitted directly to the ECB shall be transmitted to the addresses communicated by the ECB and in the format prescribed by it. In the absence of such a requirement, the documents shall be submitted electronically to the CSSF.

The documents submitted must permit ad hoc searches, cross-sectional analyses and comparisons over time. Accordingly, their format shall be compatible with the office tools used by the CSSF and shall not restrict reading access, printing, text search or copy functions. Documents must therefore be transmitted in PDF format, with the above functionalities enabled through the appropriate settings in the “Save As” window.

According to the information linked from circular CSSF 25/902, the content of the electronic file submitted shall be identical to that of the signed paper version or the electronic version retained by the credit institution.

This news related to Circular CSSF 25/902 can be considered beneficial under CSSF-Circulars, Credit Institutions News, and Explanation.

The pre-filled example templates for many CSSF Circulars should be available at https://ratiofy.lu/templates/ from the summer of 2026.