Investment firms now required to utilize a fresh data input format provided by CSSF
Luxembourg's Financial Regulator Introduces New Process for Investment Firms
In a bid to optimize and digitalize regulatory filings, the Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial services regulator, has introduced a new process for updating information for investment firms.
The new process requires any update or change subject to prior authorisation or notification to be submitted using a dedicated Excel-based data entry form. This form must be fully completed according to the type of update or request, which can include changes such as general entity information, services and activities, management bodies, shareholders, key function holders, auditors, opening representative offices, and the use of tied agents, among others.
The dedicated Excel file includes multiple sheets tailored to different update situations. Investment firms are expected to provide all requested information in the corresponding sheet. Where appropriate, firms can also insert supporting documents in PDF format directly into the Excel file.
The completed form must then be submitted via the firm’s dedicated folder on the CSSF's secure MFT (Managed File Transfer) platform. Additionally, all supporting PDF documents should be separately uploaded into a sub-folder within the dedicated MFT folder.
It is important to note that any update request not submitted using the prescribed Excel form will be considered null and void and will not be processed. This emphasizes the strict compliance with this new standardized format.
This procedure is part of CSSF’s digital modernization initiatives, aligning with recent digital reporting changes such as the introduction of e-Identification for fund prospectuses. However, specific to investment firm information updates, the Excel form format and MFT submission is required.
In summary, investment firms must use the dedicated Excel data entry form for updates or changes subject to CSSF authorisation or notification. The Excel form contains separate sheets for different update types, and supporting PDFs can be embedded in the form and must also be separately uploaded. Submission must be made via the firm's dedicated MFT folder.
The CSSF notice applies to all investment firms in Luxembourg. Completed dedicated files should be submitted to the CSSF via the MFT's dedicated folder. The changes are effective immediately, but the CSSF did not specify a deadline for the transition to the new form.
[1] CSSF Notice 2022/xx - Update of the process for the submission of information relating to investment firms (link)
[3] CSSF Notice 2021/xx - Update of the process for the submission of information relating to investment funds (link)
- The new process for investment firms in Luxembourg, introduced by the Commission de Surveillance du Secteur Financier (CSSF), requires all updates or changes to be submitted using a dedicated Excel-based data entry form, which includes separate sheets for different update types and allows for the embedding of supporting PDFs.
- Compliance with the banking-and-insurance sector, particularly investment firms in Luxembourg, is now expected to take place digitally via the use of the prescribed Excel form for updates or changes subject to authorisation or notification. This process is part of the CSSF's ongoing efforts to optimize and digitalize regulatory filings.
