CAA Update – Teleworking And Electronic Signatures: Changes From 1 September 2023

On 13 June 2023, the Commissariat Aux Assurances (CAA) issued Circular Letter 23/10 on the teleworking of managers, key functions and other control functions and the use of electronic signatures (Circular Letter).

1. Scope

The Circular Letter applies to insurance and reinsurance undertakings supervised by the CAA (Undertakings).

2. Key Considerations

The Circular Letter includes two sets of guidance:

• guidance on the use of telework;
• guidance on the use of electronic signatures on documents to be submitted to the CAA.

2.1 Key considerations on telework

The Circular Letter starts by providing a definition of what type of activity constitutes telework and reiterates the general principle that Undertakings must have, in Luxembourg, a well-established central administration, which includes both a decision-making centre (composed of the authorised manager (dirigeant agréé), the key function holders and the support and control functions, as well as