Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 13 MARCH 2026

Bank Director And Key Function Holder Suitability Assessment Under CRD VI

Loyens & Loeff
Loyens & Loeff
Contributor
Loyens & Loeff

Loyens & Loeff

One firm: Law and Tax Loyens & Loeff is a leading independent, full-service law and tax firm in...

View firm profile
Explore more from Loyens & Loeff

Bill No. 8627, transposing the sixth Capital Requirements Directive 2024/1619 (CRD VI), introduces several changes to the suitability assessment framework for members of the management bodies...

LuxembourgCorporate/Commercial Law
Adrien Pierre
Adrien Pierre
Elena Mouzaki
Elena Mouzaki

Bill No. 8627, transposing the sixth Capital Requirements Directive 2024/1619 (CRD VI), introduces several changes to the suitability assessment framework for members of the management bodies and key function holders of credit institutions and certain financial holding companies in Luxembourg.

The revised regime aims to establish a harmonised framework across all EU member states, ensuring the timely "fit and proper" assessment of the in-scope management members and key function holders, and introduces changes to the relevant provisions of the Luxembourg law of 5 April 1993 on the financial sector, as amended (LFS). Provisions on suitability assessments are to this date spread out in various texts, including the LFS, guidelines by the European Supervisory Authorities and CSSF circulars.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

New Guidance Issued By The Luxembourg Business Registers On Beneficial Ownership Registration

The Luxembourg Business Registers has issued new guidance requiring entities held by fiducies, trusts, or foundations to look through these structures when determining beneficial ownership for registration purposes. This circular introduces significant changes to how beneficial owners must be identified and reported, aligning Luxembourg's approach with upcoming EU regulations and potentially requiring many entities to review and amend their existing registrations.
LuxembourgCorporate/Commercial Law
A&O Shearman
A&O Shearman
Article

New LBR Sanctions Regime

Luxembourg has strengthened its enforcement framework for the Register of Beneficial Owners and Trade and Companies Register, granting the Luxembourg Business Registers new administrative powers to monitor compliance and impose sanctions. Starting September 2026, entities with incomplete or inaccurate filings may face progressive penalties including daily fines, administrative deregistration, and potential dissolution.
LuxembourgCorporate/Commercial Law
Loyens & Loeff
Loyens & Loeff
Article

Luxembourg Business Registers Launches Enforcement Phase Of RCS And RBE Compliance Procedure

Luxembourg's Business Registers will begin enforcing compliance sanctions from September 2026, introducing a graduated penalty system for entities with incomplete or inaccurate RCS and RBE filings. The framework progresses from public warnings to daily fines of EUR 40 and potential deletion from the registers, with entities able to regularise their position at any stage to avoid escalating consequences.
LuxembourgCorporate/Commercial Law
Tiberghien
Tiberghien
Article

Luxembourg Business Registers Launches Enforcement Phase For RCS And RBE Compliance

Luxembourg's business registers have entered an enforcement phase targeting companies that have failed to comply with RCS (Registre de Commerce et des Sociétés) and RBE (Registre des Bénéficiaires Effectifs) requirements. Non-compliant entities now face potential penalties and administrative actions as authorities intensify their regulatory oversight. Understanding these enforcement measures and compliance obligations is critical for businesses operating in Luxembourg's jurisdiction.
LuxembourgCorporate/Commercial Law
Luther Luxembourg S.A.
Luther Luxembourg S.A.
Article

Luxembourg Business Registers Clarifies RBE Filings For Companies Held By A Trust Or Foundation

Luxembourg's Business Register has clarified how beneficial ownership rules apply when companies are held through trusts or foundations, requiring entities to register the underlying trust or foundation's beneficial owners rather than applying the standard corporate ownership test. This interpretation, issued without a transitional period, means affected entities must immediately review their beneficial ownership filings to ensure compliance with the Register's position.
LuxembourgCorporate/Commercial Law
Tiberghien
Tiberghien
Article

OECD Releases New Pillar Two Guidance, Updated GIR And Framework For Legislative Reviews

The OECD has released new administrative guidance on Pillar Two's Global Anti-Base Erosion (GloBE) Rules, addressing explicitly conditional taxes and QDMTT safe harbour operations. The package includes an updated GloBE Information Return incorporating permanent safe harbours and establishes a peer review framework for assessing whether domestic legislation aligns with international standards.
NetherlandsTax
Loyens & Loeff
Loyens & Loeff
Article

Introduction Of A New Swiss Transparency Register

Switzerland's new Legal Entities Transparency Act introduces a centralised federal register of beneficial owners, fundamentally changing how Swiss companies must identify, document and report ultimate ownership and control structures. The regime imposes strict reporting deadlines beginning in late 2026, with criminal sanctions for non-compliance reaching up to CHF 500,000 for intentional breaches. Companies must now navigate complex look-through requirements, enhanced documentation obligations, and ongoing
SwitzerlandCorporate/Commercial Law
Loyens & Loeff
Loyens & Loeff
Article

OECD Consultation On Chapter VII (Intra-Group Services): Submitted Comments And Key Considerations

The OECD's proposed revisions to Chapter VII of the Transfer Pricing Guidelines represent the most extensive rewrite of intra-group services guidance in years, introducing new requirements for accurate delineation, expanded benefit testing, and dedicated documentation standards. Loyens & Loeff's Transfer Pricing team has submitted detailed comments assessing whether these changes reduce compliance burdens or risk increasing double taxation for multinational enterprises.
NetherlandsTax
Loyens & Loeff
Loyens & Loeff