The Luxembourg Commission de Surveillance du Secteur Financier issued Circular CSSF 25/870 amending its revised long form report framework for investment firms. From the financial year ending 31 December 2024, all investment firms incorporated under Luxembourg law, including their branches, must prepare a revised long form report, extending the requirement beyond the sample of firms covered for the 31 December 2023 year-end. The reporting framework under Circular CSSF 24/853 comprises four dedicated reports, but the CSSF is applying a more proportionate approach for investment firms that are subject to the revised long form report for the first time from the 31 December 2024 year-end and are assessed as comparably lower risk (Partial Scope IF). These firms must submit three reports for the time being: the self-assessment questionnaire, a MiFID report on the protection of clients’ financial instruments and funds prepared by an approved statutory auditor (réviseur d’entreprises agréé), and an AML/CFT report prepared by the same auditor; Partial Scope IF are temporarily exempt from agreed-upon procedures reports. The revised framework also limits the auditor’s work compared with Circular CSSF 03/113 and focuses on certain MiFID and AML/CFT requirements, while the 2024 self-assessment questionnaire remains broadly consistent with the prior year with limited additions, including guidance on client asset protection and Digital Operational Resilience Act preparedness. The revised long form report must be documented and uploaded via the CSSF eDesk platform, and the portal for the financial year ending 31 December 2024 is expected to be accessible in the following weeks. The CSSF plans to hold a virtual information workshop in the coming weeks to guide firms, in particular Partial Scope IF.
Luxembourg Commission de Surveillance du Secteur Financier 2025-01-09
Luxembourg Commission de Surveillance du Secteur Financier extends revised long form report requirement to all Luxembourg investment firms and introduces lighter regime for lower-risk first-time filers
The Luxembourg Commission de Surveillance du Secteur Financier issued Circular CSSF 25/870, amending the long form report framework for investment firms from the financial year ending 31 December 2024. Investment firms must prepare a revised long form report, with Partial Scope Investment Firms submitting three specific reports and temporarily exempt from agreed-upon procedures reports. The revised framework focuses on MiFID and AML/CFT requirements, with documentation uploaded via the CSSF eDesk platform.