Circular CSSF-CODERES 24/20
CSSF
Purpose & Regulatory Basis
The CSSF, in its role as Luxembourg's resolution authority, confirms the official application of the EBA’s Guidelines (EBA/GL/2024/04) for the resubmission of historical data within both supervisory and resolution reporting frameworks. This formalizes alignment with the EBA’s European-wide approach, enhancing consistency in regulatory practices. The CSSF has updated its Resolution Reporting and Notification Requirements accordingly.
Scope of Application
The circular applies to a wide range of Luxembourg-based financial entities defined under Article 2 of the Law of 18 December 2015, including:
Credit institutions and certain investment firms,
Their subsidiaries and holding companies (financial or mixed), both domestic and EU-based, where resolution obligations apply at the individual, sub-consolidated, or consolidated levels.
What the EBA Guidelines Cover
When resubmission is needed: Entities must resubmit corrected current data plus historical data going back at least one calendar year (depending on reporting frequency) when errors are identified.
When resubmission may not be required: The guidelines also outline specific cases—which may include de minimis errors—where resubmission of past data may be deemed unnecessary.
Role of authorities: CSSF, the Single Resolution Board (SRB), or the EBA may request resubmission for additional periods if supervisory or resolution needs warrant it.
Non-delegation of core duties: The guidelines reinforce that institutions must continue submitting data that is high-quality, accurate, consistent, and complete—the guidelines aid compliance but do not replace primary obligations.
Timing of Application
The circular came into effect immediately upon publication on 17 October 2024.
Why It Matters to Your Readers
Reflects CSSF’s dedication to supervisory convergence and regulatory harmonization across the EU.
Clarifies institutional responsibilities around correcting historical data, helping to ensure regulatory accuracy and transparency.
Demonstrates CSSF’s commitment to robust resolution oversight, with clearly defined protocols for data governance in sensitive periods.