Circulaire CSSF 23/834

Circular CSSF 23/834 mandates the use of the IMAS Portal for specific supervisory processes within the SSM.
The IMAS portal serves as a digital interface to enhance efficiency, communication, and transparency in these processes, aligning with the commitment of the ECB and national competent authorities. Importantly, utilizing the IMAS Portal does not alter the legal framework or the distribution of legal responsibilities between the CSSF and the ECB within the SSM. This circular replaces and supersedes Circular CSSF 20/763 from December 2020 and Circular CSSF 21/781 from September 2021.
All credit institutions incorporated under Luxembourg law, significant and less significant institutions, are in scope of this circular, if they are involved in supervisory processes such as qualifying holdings, submitting passporting notifications, conducting licensing procedures, and initiating voluntary withdrawals of licensing authorizations. Additionally, significant institutions have additional obligations if they are involved in supervisory processes such as appointing members of the management body, conducting authorisation procedures for financial holding companies, performing credit quality on-site inspections, addressing internal model changes and extensions, and notifying outsourcing arrangements
However, it is important to note that the IMAS Portal should not be used for certain supervisory processes, such as applications for third-country branches, license lapsing notifications, and specific fit and proper assessments.
By utilizing the IMAS Portal, the SSM aims to streamline file processing and enhance transparency in communication. Consequently, the CSSF, in line with other national competent authorities within the SSM, has made the use of the IMAS Portal mandatory for the supervisory processes outlined in this circular.
Instructions for creating, activating, and managing an IMAS account are available on the IMAS Portal. For less significant institutions, the registration document should be sent to the CSSF agent responsible for the bank, along with a copy to banking_license@cssf.lu. Registration and use of the IMAS Portal are free of charge.
With the introduction of the IMAS Portal, the submission of original documents is no longer necessary. However, the relevant parties must ensure that the electronically sent documents are accurate copies of the originals, which should be made available upon the CSSF’s request. It is emphasized that not only initial applications but also subsequent information exchanges should take place within the IMAS Portal, with the use of external emails limited to necessary communication to complete the documentation process.
For technical issues with the IMAS Portal or the ECB Identity Portal, users can contact the ECB Support Center via email at supportcenter@ecb.europa.eu or by phone at +49 69 1344 7766.