Luxembourg Financial Reporting Deadlines

Register of Information (ICT Third-Party Arrangements)

• Frequency: Annual (based on 31 Dec ref date)
• Deadline: 1 April – 15 April (annually)
• Reference: Circular CSSF 25/882
• Channel: eDesk Portal (CSV)

Insight: First submission for 31/03/25 ref date was extended to 31/05/25.

Notification of Planned Critical/Important ICT Arrangement

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: At least 3 months before planned contract
• Reference: Circular CSSF 25/882
• Channel: CSSF Forms

Insight: Notice period is reduced to 1 month if the provider is a Luxembourg-based Support PFS.

Major ICT-Related Incident (Initial Notification)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Within 4 hours of classification
• Reference: Circular CSSF 25/893
• Channel: eDesk Portal / API (S3)

Insight: Replaces Circular 24/847 for DORA entities. Timelines are set by DORA RTS.

Major ICT-Related Incident (Intermediate Report)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Within 72 hours of initial notification
• Reference: Circular CSSF 25/893
• Channel: eDesk Portal / API (S3)

Major ICT-Related Incident (Final Report)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Within 1 month of intermediate report
• Reference: Circular CSSF 25/893
• Channel: eDesk Portal / API (S3)

Estimation of Aggregated Annual ICT Incident Costs/Losses

• Frequency: Annual
• Deadline: Deadline not yet specified (Circular applies from 31/05/25)
• Reference: Circular CSSF 25/892
• Channel: TBD

Insight: New annual report under DORA.

Major ICT-Related Incident (Initial Notification)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Within 4 hours of classification
• Reference: Circular CSSF 24/847
• Channel: eDesk Portal

Insight: The 4-hour clock starts at classification, not detection. This is a critical procedural distinction.

Major ICT-Related Incident (Intermediate Report)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Within 3 working days of initial notification
• Reference: Circular CSSF 24/847
• Channel: eDesk Portal

Major ICT-Related Incident (Final Report)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Within 1 month of intermediate report
• Reference: Circular CSSF 24/847
• Channel: eDesk Portal

ICT and Security Risk Assessment

• Frequency: Annual (Principle-Based)
• Deadline: Once per year (no target date)
• Reference: Circular CSSF 20/750 (as amended by 25/881)
• Channel: Internal Document (available to CSSF on request)

Insight: This is a principle-based obligation, to be performed annually or upon any major ICT change.

PSP ICT Assessment

• Frequency: Annual
• Deadline: Before 31 March (annually)
• Reference: Circular CSSF 25/880
• Channel: eDesk Portal

Insight: This is a hard deadline for PSPs, carved out of the 20/750 framework.

Long Form Report – Self-Assessment Questionnaire (SAQ)

• Frequency: Annual (based on fin. year-end)
• Deadline: Within 3 months of financial year-end
• Reference: Circular CSSF 22/821 (as amended)
• Channel: eDesk Portal

Insight: The deadline was T+4 months for the first year of application (2022 FY).

Long Form Report – REA Reports (Auditor Reports)

• Frequency: Annual (based on fin. year-end)
• Deadline: Within 5 months of financial year-end
• Reference: Circular CSSF 22/821 (as amended)
• Channel: eDesk Portal

Long Form Report – REA Management Letter

• Frequency: Annual (based on fin. year-end)
• Deadline: Within 6 months of financial year-end
• Reference: Circular CSSF 22/826 (as amended by 23/845)
• Channel: eDesk Portal

Self-Assessment Questionnaire (SAQ) for EU Branches

• Frequency: Annual (based on fin. year-end)
• Deadline: Within 3 months of financial year-end
• Reference: Circular CSSF 22/827
• Channel: eDesk Portal

Insight: Aligns EU branches with the 22/821 LFR framework.

Support PFS – Self-Assessment Questionnaire (SAQ)

• Frequency: Annual (based on fin. year-end)
• Deadline: Within 7 months of financial year-end
• Reference: Circular CSSF 24/850
• Channel: MFT / Mail

Insight: Do not confuse with the T+3m SAQ for Credit Institutions. This deadline is T+7m.

Support PFS – Descriptive Report

• Frequency: Annual (based on fin. year-end)
• Deadline: Within 7 months of financial year-end
• Reference: Circular CSSF 24/850
• Channel: MFT / Mail

IFR Prudential Reporting (Class 2)

• Frequency: Quarterly
• Deadline: Quarterly (per EBA calendar)
• Reference: Circular CSSF 21/784 (Reporting Handbook)
• Channel: eDesk / API (S3)

IFR Prudential Reporting (Class 3)

• Frequency: Annual
• Deadline: Annually (per EBA calendar)
• Reference: Circular CSSF 21/784 (Reporting Handbook)
• Channel: eDesk / API (S3)

UCI Financial Information (U1.1 Report)

• Frequency: Monthly
• Deadline: Within 10 calendar days of month-end
• Reference: Circular CSSF 15/627 (as amended by 25/871)
• Channel: eDesk / API (S3) (XML)

Money Market Fund (MMF) Reporting

• Frequency: Quarterly or Annual
• Deadline: Within 30 days of quarter/year-end
• Reference: Circulars 20/736, 25/877
• Channel: e-file / SOFiE (XML)

Insight: Frequency depends on AUM. New stress test scenarios (25/877) apply from 30/06/25 reporting.

UCI NAV Error / Non-Compliance Notification

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: 4 to 8 weeks from detection (“without delay”)
• Reference: Circular CSSF 24/856
• Channel: eDesk Portal

Insight: This circular, effective 01/01/25, replaces 02/77 and clarifies the “without delay” requirement.

ESG/Sustainability Fund Name Compliance (Existing Funds)

• Frequency: One-Off Compliance
• Deadline: By 21 May 2025
• Reference: Circular CSSF 24/863
• Channel: Prospectus filing (eDesk)

Insight: Critical, fixed compliance deadline for existing funds. New funds were subject as of 21/11/24.

IFM Notification (Start of Management)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Before commencing (ManCo/Auth AIFM) or Within 10 working days (Reg AIFM)
• Reference: Circular CSSF 25/894
• Channel: eDesk

Insight: Replaces 15/612. Applies to management of non-CSSF authorized funds.

IFM Notification (Termination/Liquidation)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Within 10 working days of event
• Reference: Circular CSSF 25/894
• Channel: eDesk

IFM Notification (Substantial Change)

• Frequency: Ad-Hoc (Event-Driven)
• Deadline: Without delay
• Reference: Circular CSSF 25/894
• Channel: eDesk

EMIR Refit (Update Legacy Trades)

• Frequency: Transitional
• Deadline: By 26 October 2024
• Reference: Circular CSSF 23/846
• Channel: N/A (TR Reporting)

Insight: This was the 180-day deadline to update all outstanding contracts to the new EMIR Refit standards.

Application of MiCA Suitability Guidelines

• Frequency: N/A (Application Date)
• Deadline: Guidelines apply as of 25 May 2025
• Reference: Circular CSSF 25/891
• Channel: N/A (Compliance)

COREP/FINREP Reporting (General)

• Frequency: “Monthly, Quarterly, Annual”
• Deadline: Per EBA Reporting Calendar
• Reference: Circular CSSF 14/593 (as amended)
• Channel: eDesk Portal / API (S3)

Insight: All submissions MUST be via eDesk/S3 as of 1 April 2025.

COREP Own Funds & Leverage (Taxonomy v4.0)

• Frequency: Quarterly
• Deadline: Extended to 30 June 2025
• Reference: Reporting Handbook v8.2
• Channel: eDesk Portal / API (S3)

Insight: This is a specific extension for the Q1 2025 (31/03/25 ref date) report, extended from 12/05/25.

ALM & LCRDA Reports (Monthly)

• Frequency: Monthly
• Deadline: Per EBA Reporting Calendar
• Reference: Reporting Handbook v8.0
• Channel: eDesk Portal / API (S3)

Insight: Migrated to eDesk/S3 as of 1 September 2024.

IRRBB Reporting (Quarterly)

• Frequency: Quarterly
• Deadline: Per EBA Reporting Calendar
• Reference: Reporting Handbook v8.1
• Channel: eDesk Portal / API (S3)

Insight: Migrated to eDesk/S3 as of 1 October 2024 (for Q3 2024 submission).