Circular CSSF 24/864

Purpose & Context

Circular 24/864 announces that the Commission de Surveillance du Secteur Financier (CSSF) has adopted the EBA Guidelines (EBA/GL/2024/04) concerning the resubmission of historical data in case of errors, inaccuracies, or changes under the EBA’s supervisory and resolution reporting framework. This move aligns CSSF’s enforcement practices with European supervisory convergence goals.

What the Guidelines Cover

• They establish a harmonized approach for institutions (credit institutions, investment firms, payment institutions) to resubmit corrected historical data to supervisory and resolution authorities when the previously submitted data contains errors or inconsistencies.

• The approach considers both the reporting frequency and the reference date, including how far back corrections must go relative to the end of the previous calendar year.

• The Guidelines specify circumstances where resubmission is not required, helping clarify expectations for institutions and authorities.

• Importantly, they do not override institutions' primary obligation to submit high-quality, consistent, and complete data.

• CSSF retains its authority to require additional resubmissions on a case-by-case basis, beyond the common framework.

Scope of Application

This circular applies to all supervised entities that use the EBA's supervisory reporting framework, where the CSSF is the competent authority. The scope includes reporting at the individual, sub-consolidated, and consolidated levels, depending on the entity’s reporting obligations.

Immediate Effect

The circular took effect immediately upon issuance on 28 October 2024.

Why This Matters for Your Blog Readers

• The circular highlights CSSF’s commitment to upholding strong data quality and consistency across the EU’s financial reporting landscape.

• It clarifies how institutions should correct and resubmit inaccurate historical data, promoting transparency and supervisory alignment.

• It reassures stakeholders that robust oversight mechanisms remain in place—even while providing a clearer framework for corrections.