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ARTICLE · 16 MARCH 2026

CSSF Circular 26/906: A Consolidated Framework For Governance And Risk Management In Payment And E-money Institutions

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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The Commission de Surveillance du Secteur Financier (CSSF) published its new CSSF circular 26/906 on central administration...

LuxembourgFinance and Banking

The Commission de Surveillance du Secteur Financier  (CSSF) published its new CSSF circular 26/906 on central administration, internal governance and risk management (Circular) applicable to payment institutions (PIs) and electronic money institutions (EMIs) whose home member state is Luxembourg, including their branches, as well as to Luxembourg branches of PIs and EMIs whose home member state is outside the European Economic Area (Institutions).

The Circular intends to clarify the modalities of application of the requirements laid down in the Law of 10 November 2009 on payment services, as amended (LPS) which requires the Institutions to dispose of robust internal governance arrangements, effective processes to identify, manage, monitor and report risks as well as adequate internal control mechanisms.

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