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ARTICLE · 28 JANUARY 2026

Circular CSSF 26/906: New Governance Framework For Payment Institutions And Electronic Money Institutions

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On 20 January 2026, the CSSF published a new Circular 26/906 on central administration, internal governance and risk management applicable to payment institutions (PIs) and electronic money institutions...

LuxembourgFinance and Banking
Adrien Pierre
Adrien Pierre
Elena Mouzaki
Elena Mouzaki

On 20 January 2026, the CSSF published a new Circular 26/906 on central administration, internal governance and risk management applicable to payment institutions (PIs) and electronic money institutions (EMIs) (the Circular  or Circular 26/906). This new framework is a significant paradigm shift for PIs and EMIs and aims to align the governance obligations of these entities with those already applicable to banks (Circular CSSF 12/552) and investment firms (Circular CSSF 20/758).

Former regulatory framework and the importance for robust PI/EMI governance

Internal governance is a key point of attention of the CSSF in relation to regulated entities and has been flagged as such in the CSSF annual reports of the last few years.

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