Circulaire CSSF 23/845

Circular CSSF 23/845 provides amendments to Circular CSSF 22/821, focusing on the LFR, and Circular CSSF 22/826, addressing practical rules for the statutory audit mandate of approved statutory auditors. The primary objective is to enhance clarity based on industry feedback and align the SAQ content with supervisory priorities.
The revised SAQ now encompasses five thematic sections. First, credit and counterparty risk are expanded, responding to industry feedback and broadening the assessment scope. Second, IRRBB and CSRBB are addressed, specifically considering non-trading book activities to ensure a comprehensive evaluation of risks. Third, liquidity risk scrutiny is intensified, focusing on liquidity-related aspects for a more thorough examination. Fourth, alignment with PSD 2 requirements is emphasized in the context of strong customer authentication and secure communication. Lastly, the circular recognizes the increasing importance of environmental considerations in the financial landscape, introducing a thematic section on climate-related and environmental risks.
Circular CSSF 23/845 introduces changes regarding reports mandated for approved statutory auditors. Notably, the requirement for AUP reports on a recurring basis is eliminated. While the CSSF retains the right to request AUPs on an ad hoc basis in the future, no such reports are expected for financial year-end 2023 information.
Additionally, the circular amends Circular CSSF 22/826, addressing practical rules for the statutory audit mandate of REA. The submission deadline for the management letter is adjusted to better align with the submission timeline for reports established under Circular CSSF 22/821 on the Long Form Report.
For detailed information on particular amendments (with tracked changes) to Circular CSSF 22/821, refer to Annex I, and for amendments to Circular CSSF 22/826, consult Annex II**.