Circular 19/709


Circular 19/709

28 June 2019

Regulatory News Alert

On 25 February 2019, the CSSF published Circular 19/709 (the Circular) concerning the introduction of quarterly internalised settlement reporting requirements pursuant to Article 9(1) of EU Regulation No 909/2014 (CSDR).

The Circular is addressed to:

  • All credit institutions incorporated under Luxembourg law (with the exception of the credit institutions that have requested a CSD license under Article 17 of CSDR)
  • Luxembourg branches of non-EU credit institutions
  • Investment firms providing services listed at Annex II Section C(1) of the Law on the Financial Sector of 5 April 1993 (with the exception of investment firms of this type that have requested a CSD license under Article 17 CSDR)

The Circular reminds that the internalised settlement reporting requirements are specified in the Commission Delegated Regulation (EU) 2017/391 and that the template forms and procedures for this reporting and its transmission are outlined in the Commission Implementing Regulation EU 2017/393.

In order to clarify the scope and process of internalised settlement reporting, reporting entities1 shall rely on ESMA guidelines published on 28 March 2018

In accordance with point 17 of these ESMA guidelines, reporting entities will have to submit the CSSF:

  • One report with their activities in Luxembourg (including the activity of their branches in Luxembourg)
  • Separate reports for their branches’ activities per EU Member State 
  • One report for their third country branches’ activities

The CSSF reminds that the first internalised settlement reporting should be sent to the CSSF via the transmission channels E-File or SOFie within 10 working days from the end of the first quarter. An xml file complying with the naming convention presented in annex to the Circular should also be sent before 12 July 2019 at the latest.

How can Deloitte help?

To prepare for the new reporting challenges, Deloitte Luxembourg established Deloitte Solutions in 2016. Deloitte Solutions is a PSF entity subject to strict IT security and data confidentiality standards. Deloitte’s Transaction Regulatory Reporting services (T2R) are handled in the Deloitte Solutions’ environment.

Deloitte has integrated the new CSDR reporting regime in its transaction reporting solution, thus becoming one of the only platforms in Europe designed to manage CSDR, EMIR, MiFIR and SFTR reporting for clients in a cost and resource-efficient manner.

With its T2R services, the Deloitte team combines its regulatory knowledge with smart technical solutions, and manages the transactional reporting for its clients as a dedicated agent from A to Z.

Deloitte’s advisory specialists will also help you design and implement your renewed business strategy and support you in light of new reporting challenges.

Thanks to its RegWatch Kaleidoscope service, Deloitte helps you stay ahead of the news to leverage regulations for your strategic business objectives.


1 The list of entities that shall submit quarterly reports to the CSSF includes credit institutions, investment firms, Professional of the Financial Sector (PFS) as well as support PFS.

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Simon Ramos
Partner – IM Advisory & Consulting 
Tel : +352 45145 2702

Laurent Collet
Partner – Strategy Regulatory & Corporate Finance
Tel : +352 45145 2112

Kevin Demeyer
Director – Strategy Regulatory & Corporate Finance
Tel : +352 45145 3808

Benoit Sauvage
Director – RegWatch, Strategy & Consulting
Tel : +352 45145 4220

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