The present CSSF circular covers the calculation of the 2024 ex-ante contribution to the SRF. Article 67 of Regulation (EU) No 806/2014 outlines the establishment of a SRF under the responsibility of the SRB for Member States participating in the SSM. The SRF aims to provide financial resources for the resolution of credit institutions and BRRD investment firms within the Single Resolution Mechanism. The Commission Delegated Regulation (EU) 2015/63 and Council Implementing Regulation (EU) 2015/81 specify the methodology for the calculation of the contribution to the SRF and the obligations of credit institutions regarding necessary information in a Single Resolution Mechanism context.
The Initial Period for the constitution of the SRF is expected to end on 31 December 2023. After this date, contributions to the SRF will be raised if the available financial means in the SRF diminish below 1% of the amount of covered deposits of all credit institutions authorized in all Member States participating in the BU. Branches established in Luxembourg by institutions with their head office outside the European Union are not targeted by this circular as they will be covered by the Luxembourg Resolution Fund.
The SRB will verify in early 2024 whether the available financial means in the SRF are equal to at least 1% of covered deposits held in the BU. Based on this verification exercise, the SRB will decide whether ex-ante contributions to the SRF will be calculated and collected in the 2024 contribution period. The SRB needs a certain amount of information as expressed in the kick-off letter and its decision dated 13 September 2023 on data formats etc..
The purpose of this circular is to launch the data collection exercise, which is done in XBRL format. The SRB has provided the data reporting form along with guidance. This information is also made available on the CSSF’s website. The duly completed XBRL file has to be sent to the CSSF at the latest by 12 January 2024 at 24:00 CET. In case not all required information is transmitted correctly by that date, the SRB shall use estimates or its own assumptions for the calculation of the 2024 contribution of the concerned credit institution to the SRF. In specific cases, the SRB may assign the credit institution concerned to the highest risk adjusting multiplier, for the calculation of the institution’s contribution to the SRF.
Each credit institution that directly or as part of a group falls under direct ECB supervision must make available to the resolution department of the CSSF their AA, which will be transmitted to the SRB. The documents have to be sent to the CSSF at the latest by 23 February 2024. Banks which do not appear on the list in Annex 6 do not have to send in any AA.
In case restatements for the previous years must be taken into account, please inform or re-inform proactively the CSSF of your intention to send these files and of the collection years concerned by 30 November 2023. The format to be used is the one that was relevant for the contribution period (i.e. XBRL for 2023 data collection exercise and Excel for the previous exercises). For restatements as well, each credit institution that directly or as part of a group falls under direct ECB supervision (see Annex 6), unless it is subject to the lump-sum payment, must make available to the resolution department of the CSSF an AA within the above-mentioned deadline. However, by way of exception, a (new) AUP report from an auditor on the restated data point is not required under the following conditions:
– the restatement is due following an auditor’s report in a previous cycle where the erroneous data point was identified;
– the same auditor’s report expressly mentioned the former figure and the new value that should be resubmitted for the purpose of calculating the restatement.
For any questions concerning this circular please contact Mr. Klaus Söllner (e-mail:
klaus.sollner@cssf.lu), Mr. Bertrand Toulmonde (e-mail: bertrand.toulmonde@cssf.lu), Mr. François
Basso (e-mail: francois.basso@cssf.lu).
All annexes are accessible via the links at the end of the present circular, which we included in full in the background links of this event.