Reports foreseen by Circulars CSSF 21/788, 21/789 and 21/790, applicable as from year-end 31 December 2023, now available in eDesk and information on main updates

The CSSF published Circulars CSSF 21/788, 21/789, and 21/790 back on 22 December 2021. These circulars introduced new reports for IFMs and UCIs, aimed at enhancing the risk-based supervision of the CSSF for prudential and AML/CFT purposes.
These new reports consist of a self-assessment questionnaire, separate report, and CSSF AML/CFT external report. To facilitate compliance with these reporting requirements, the CSSF made the reports available in the CISERO module on its eDesk portal starting from 10 January 2022 for IFMs and 31 March 2022 for UCIs. However, as of 15 November 2023, entities with financial year-ends on or before either 31 December 2023 and 31 January 2024 can access the reports in CISERO. Reports with financial year-ends after 31 January 2024 will be accessible three months prior to their respective year-end.
The CSSF notes that it has incorporated some limited updates to the questionnaires included in the reports based on feedback from industry participants received through both submissions to CISERO mailbox cisero@cssf.lu as well as applicable regulatory requirements. These updates primarily aim to clarify certain questions and complement specific topics based on regulatory requirements.
In response to industry feedback and aligning with its priorities, a short AML/CFT section has been added to the separate report for UCIs falling under Circular CSSF 21/790 that have designated an IFM outside Luxembourg.
Furthermore, an IT solution is now available from 15 November 2023 onwards to optimize filling out self-assessment questionnaires specifically for UCIs falling within Circular CSSF 21/790’s scope. This solution allows stakeholders to fill in the questionnaire through a structured file transmitted to the CSSF via S3 protocol, which will then prefill the questionnaire available on the CSSF eDesk portal. Users can manually update prefilled data through S3 within eDesk. Alternatively, manual input of responses directly into the eDesk SAQ online form remains an option.
For further information on using this new solution, stakeholders are advised to consult the dedicated user guide provided by CSSF entitled “DESK – Collective Investment Sector Reporting Tool“, which also was updated on 15 November 2023 with a Chapter 5 on „Preloading the Self-assessment questionnaire for the funds available in eDesk via S3“. The CSSF notes that, the „transmission of a fund’s Self-assessment questionnaire via S3 is only authorised for an exercise end date greater than 31/12/2023.“