Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 29 FEBRUARY 2024

New CSSF Circular Introduces ICT-related Reporting Obligations For All Regulated Entities Of The Financial Sector

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

On 5 January 2024, the Commission de Surveillance du Secteur Financier (CSSF) published a new Circular No 24/847 (Circular 24/847) implementing a new ICT-related incident reporting framework.

LuxembourgFinance and Banking
Adrien Pierre
Adrien Pierre
Vanesa Gomez Pena
Vanesa Gomez Pena
Elena Mouzaki
Elena Mouzaki

On 5 January 2024, the Commission de Surveillance du Secteur Financier (CSSF) published a new Circular No 24/847 (Circular 24/847) implementing a new ICT-related incident reporting framework. The new rules, imposing a new obligation on all supervised entities of the financial sector to classify ICT-related incidents and to report those qualifying as "major" to the CSSF in accordance with a detailed process and within a specific timeframe, will become applicable as from 1 April 2024 (and exceptionally as from 1 June 2024 with regard to investment funds and fund managers).

Who is in scope?

Circular 24/847 introduces a new supervisory regime for ICT-related incidents, i.e., unplanned events threatening the network and information system security and jeopardising the availability, authenticity, integrity and confidentiality of data and/or services provided by in-scope entities.

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

CRD VI: The EU's Cross-border Banking Rules Are Changing For Non-EU Institutions. Are You Ready?

The EU's third-country branch regime under CRD VI fundamentally changes how non-EU banks can serve European clients, requiring most institutions to establish authorized branches or subsidiaries by January 2027. With national transposition underway and a critical grandfathering deadline already passed, affected institutions must urgently assess their EU activities, evaluate available exemptions, and determine whether their current operating models remain viable under the harmonized framework.
European UnionFinance and Banking
DLA Piper
DLA Piper
Article

CSSF Imposes Fine For AML And Sanctions Compliance Violations

Luxembourg's CSSF imposed a €56,000 fine on Stonehage Fleming Luxembourg S.A. for multiple compliance failures, including significant delays in processing sanctions screening alerts and implementing changes to screening lists. At the time of inspection, hundreds of alerts had been treated with substantial delays and 42 alerts remained completely unnoticed by the financial services provider.
LuxembourgFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

AIFMD II: Key Implementation Developments In Luxembourg

Two years on from the entry into force of Directive (EU) 2024/927, commonly referred to as AIFMD II, the 16 April 2026 transposition deadline has passed, and the state of play across the EU is best described as uneven, with compliance posture increasingly dependent on where an AIFM is authorised. However, Luxembourg, which hosts the largest shares of EU AIFs within the Union, transposed the Directive without material gold-plating.
European UnionFinance and Banking
Maples Group
Maples Group
Article

The AIFMD II Directive And Financing Transactions

The Luxembourg law of March 3, 2026 transposed the AIFMD II Directive into national law, introducing significant changes to the regulatory framework governing alternative investment funds. This article examines the practical implications for financing transactions involving Luxembourg AIFs, analyzing how the new rules on loan origination, leverage caps, concentration limits, and enhanced disclosure requirements affect both lenders and borrowers in structured finance arrangements.
LuxembourgFinance and Banking
Dechert
Dechert
Article

Reverse Solicitation: The Exception That Regulators Expect To Remain Exceptional

Reverse solicitation remains one of the most scrutinised concepts in fund distribution, offering a legitimate route for investment when approached entirely on the investor's initiative. Yet the distinction between genuine unsolicited interest and marketing activity carries significant regulatory consequences, requiring AIFMs to navigate narrow fact-specific exceptions rather than treating it as a designed distribution model.
LuxembourgFinance and Banking
Loyens & Loeff
Loyens & Loeff
Article

Luxembourg Private Funds Organised As Companies: How To Make Them Fit For Purpose

Luxembourg's partnership limited by shares (SCA) offers private fund managers a compelling corporate alternative to the special limited partnership structure, particularly for EU family offices and high-net-worth individuals. When combined with the RAIF regime, this vehicle achieves tax neutrality while maintaining the corporate governance framework that certain investors prefer. The SCA-RAIF structure addresses key legal and tax considerations while providing flexibility for secondary strategies, fund-of-f
LuxembourgFinance and Banking
Loyens & Loeff
Loyens & Loeff
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