Evolution of prudential reporting for payment institutions, electronic money institutions and crypto-asset service providers

The CSSF is modernising the prudential reporting framework applicable to payment institutions (PIs), electronic money institutions (EMIs) and crypto-asset service providers authorised under Article 63 of MiCAR¹ (CASPs). The current Excel-based submission process will be replaced by a more integrated and user-friendly reporting interface within the CSSF’s eDesk platform.¹

CSSF eDesk is the CSSF’s online portal through which supervised entities in Luxembourg’s financial sector submit regulatory filings, prudential reports, fund sector data, cross-border marketing notifications, and other mandatory communications to the regulator. Launched in 2018 initially for fund industry attestation requests, it has since become the CSSF’s preferred platform for virtually all digital exchanges with the industry, offering both manual form-based submission and automated API (S3) transmission free of charge.

 

Main Objectives of the Project

This initiative aims to:

• Modernise and standardise data collection through eDesk, the CSSF’s preferred platform for exchanges with supervised entities.
• Collect more accurate, structured and relevant information tailored to current supervisory needs.
• Perform automated data integrity checks before submission, reducing errors and manual interventions.
• Enhance productivity and efficiency for both the CSSF and supervised entities by facilitating better data exploitation and cross-referencing.
• Reduce the administrative burden on entities by centralising recurring information requests (payment volumes, human resources, shareholding, branches, distributors, etc.) that were previously handled through separate manual requests.
• Improve monitoring of reporting obligations with automated reminders for missed deadlines.
• Streamline and structure recurring periodic reporting-related communications, replacing email exchanges with direct interactions within eDesk.

 

Key Features of the New Reporting

• A dedicated CSSF circular (to be published) will replace the existing Circulars CSSF 11/511 and 11/522 which contain information regarding reporting for PIs and EMIs and introduce specific reporting obligations for CASPs authorised under Article 63 of MiCAR.
• Reporting forms will be dynamic and tailored to each entity’s licence (PI, EMI with or without e-money tokens issuance, CASP) and specific characteristics (e.g. foreign branches), so entities will only complete the relevant sections.
• On its website CSSF sets out the indicative information that will be required under the new reporting framework and provides, for certain data points, guidance on the expectations towards the entities, enabling them to prepare in advance for this new reporting.

 

Advanced eDesk functionalities

The new module will include:

• Automatic formulas and data carry-overs to ensure consistency.
• Real-time automated integrity controls that flag inconsistencies or errors during data entry.
• Possibility for the entities to add qualitative comments directly into a textbox within the tool.
• Optional API connection to entities’ internal systems for automated quantitative data feeding, significantly reducing manual input and error risk.
• Two submission options will be available: manual completion and submission directly via the eDesk interface, or automated submission via S3 using a JSON file
• Centralised communication and follow-up questions directly within the platform.

 

Reporting frequency

• Quarterly reporting covering financial information and human resources (including resources dedicated to control functions).
• Monthly reporting maintained solely for funds segregation.
• Annual section covering shareholding structure, branches, agents and distributors (previously requested on an ad hoc basis).

This rationalisation will lighten the overall administrative load while improving data quality and analytical capabilities.

 

Timeline and support

• From 1 January 2027 to 31 March 2027 – Testing phase: The new reporting module will be made available to all entities concerned for testing purposes. Entities are strongly encouraged to actively test the tool and familiarise themselves with the new reporting requirements. Any reports submitted through the new module during this testing period will be considered test submissions only and will not constitute official regulatory submissions.
•  Until 31 March 2027 – Official reporting via the current channel: Entities must continue to submit all reports falling due on or before 31 March 2027 in accordance with the current requirements, irrespective of any parallel testing performed through the new module.
• From 1 April 2027 – Mandatory use of eDesk: eDesk will become the sole official channel for the submission of the reports concerned, and the previous reporting process will be discontinued. All reports with a submission deadline falling on or after 1 April 2027 must therefore be submitted via eDesk, including reports relating to a reporting period ending before 1 April 2027. For example, monthly reports relating to March 2027 but due for submission in April 2027, as well as reports relating to the first quarter of 2027, must be submitted via eDesk.

For firms, this means analysing the impact these changes will have on their reporting obligations and ensuring that internal procedures and policies reflect the new methodology. Firms should familiarise themselves with the data points set out by the CSSF² and ensure that the information required to be submitted is systematically collected. Firms should also keep an eye out for the updated CSSF circular, which will provide further detail on the new reporting requirements.

Firms should ensure that relevant personnel hold a valid and functioning LuxTrust certificate, as this is required to authenticate and access the CSSF’s eDesk portal for the submission of regulatory filings and other mandatory communications.  

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¹Evolution of prudential reporting for payment institutions, electronic money institutions and crypto-asset service providers – CSSF
²Annex 1 - Overview of the data points to be reported and preparatory guidance for entities