ESPREP-RES Reporting in Luxembourg: CSSF Real Estate Lending Data

ByRegReportingDesk

Circular CSSF 26/908 of 25 March 2026 changed how Luxembourg lenders file ESPREP-RES reporting, the semi-annual residential real estate lending indicators, and deleted the file-naming block behind this report’s internal code, ESPREP-ENNNN-YYYY-MM-RES. The underlying return under Circular CSSF 18/703 remains in force. The amended transmission section provides a dedicated eDesk approach and a JSON-based API solution using the S3 protocol. Its commercial counterpart under Circular CSSF 22/803 still names E-file, SOFiE and an ESPREP-ENNNN-YYYY-MM-CRE file, although a CSSF news release of 5 April 2024 already listed the CRE collection among its eDesk and API (S3) procedures. Both are due on 15 April and 15 October.

The two collections share a calendar, a mailbox (macropru@cssf.lu) and a macroprudential purpose. They diverge on almost everything a reporting team configures: who is in scope, the consolidation level, the size threshold, where the property may sit and the transmission channels and file-naming rules each circular prints. A team that runs them as one process risks carrying a definition from one return into the other, and the March 2026 amendment added an income rule that feeds straight into four of the RRE ratios.

Related reading: ESPREP-STT Reporting in Luxembourg: The Retired IRRBB Stress Test

The fixed calendar, as the two circulars set it:

  • 15 April: RRE data at the 31 December reference date; CRE outstanding exposures at 31 December plus new CRE exposures issued between 1 July and 31 December.
  • 15 October: RRE data at the 30 June reference date; CRE outstanding exposures at 30 June plus new CRE exposures issued between 1 January and 30 June.
  • RRE holiday rule: when the 15th falls on a holiday, the RRE deadline moves to the preceding business day. Circular 22/803 states no equivalent rule for CRE.
  • CRE threshold date: the EUR 250 million test runs on the FINREP figure at 31 December of the year before submission.

The residential return rests on Circular CSSF 18/703 of 17 December 2018, “Introduction of a semi-annual reporting of borrower related residential real estate indicators”. It has been amended three times: by Circular CSSF 20/737 (19 February 2020), Circular CSSF 21/772 (7 May 2021) and Circular CSSF 26/908 (25 March 2026). The circular is addressed to all lenders in residential real estate and describes itself as a macroprudential risk monitoring framework for the Luxembourg residential market, based on Recommendation ESRB/2016/14 of 31 October 2016 on closing real estate data gaps, as amended by Recommendation ESRB/2019/3.

The commercial return rests on Circular CSSF 22/803, dated 18 March 2022 and listed on the CSSF website from 21 March 2022. The CSSF issued it as the national designated authority, following up on ESRB/2019/3, and made it applicable from its publication date. The CSSF’s document page for the circular lists no amendment since.

Both circulars trace back to the same European text. ESRB/2016/14 was published in OJ C 31 of 31 January 2017. ESRB/2019/3, adopted on 21 March 2019 and published in OJ C 271 of 13 August 2019, rewrote the commercial real estate part.

As amended, Recommendation C(1) recommends that national macroprudential authorities implement a risk monitoring framework for their domestic CRE sector. Its lender-side indicators are CRE lending flows and stocks, non-performing CRE loans and loan loss provisions, and weighted averages of LTV-O, LTV-C, ICR and DSCR, with the information relating to credit providers on a solo basis. The CSSF’s CRE template mirrors that list, down to the solo-basis choice.

Neither Circular 18/703 (in its consolidated form) nor Circular 22/803 cites an article of the Law of 5 April 1993 on the financial sector as the power behind the collection. The ESRB recommendation speaks to national macroprudential authorities; the request that reaches a Luxembourg lender is the CSSF circular itself. The residential text gained a second anchor in 2021, when Circular 21/772 stated that its changes include the data needed to monitor compliance with CSSF Regulation No 20-08 of 3 December 2020, the regulation laying down the conditions for granting loans for residential property located on Luxembourg territory.

Who must report: the EUR 10 million RRE exclusion and the EUR 250 million CRE threshold

The residential circular itself sets no size threshold. Its addressees are lenders in residential real estate, and the CSSF’s document page files it under credit institutions. The CSSF’s Questions and Answers on Circular 18/703 (version of 18 February 2020), which the CSSF still publishes with the circular, add an exclusion: a bank whose total outstanding exposure to eligible residential real estate credit does not exceed EUR 10 million is excluded from reporting, and a bank with no exposures in scope is not required to send a “zero report”.

The loan scope is tight: loans taken to purchase residential real estate in Luxembourg and secured by real estate collateral located in Luxembourg. Residential real estate covers existing dwellings, dwellings to be built under contract and land that can be used to build dwellings. A footnote brings in owner-occupied and buy-to-let loans, any loan contracted through a real estate savings plan (the circular names BSH and BHW), and renovation loans secured by real estate. Renovation loans without real estate security stay out.

Loans granted to a legal entity are excluded, including loans that reach individual investors through a civil real estate company (SCI) or a SOPARFI. The circular sends that credit to the commercial real estate collection and notes that it also appears in AnaCredit reporting.

On consolidation, the RRE workbook’s cover page asks for the highest level of consolidation available, coded “C”, “N” or “L”, and states that data input is at debtor level (a group of connected debtors), with the collection meant to be exhaustive.

Circular 22/803 addresses all credit institutions and all branches of EU and non-EU credit institutions that grant commercial real estate loans. Its threshold is EUR 250 million, measured on FINREP at the lowest solo level: Table 18, row 0140, column 010, which the circular describes as the gross carrying amount of loans and advances to non-financial corporations, of which loans collateralised by commercial immovable property. Our FINREP reporting explainer covers where that template sits in the individual FINREP set. The CRE data itself is also reported at the lowest solo level, which the circular defines as the individual level excluding foreign branches.

Falling under the threshold changes the content of the file and leaves the filing in place. Section 2.2 of the circular says that where the FINREP amount did not exceed EUR 250 million at 31 December of the previous year, the lender submits blank reports in the current year. A lender under the line still owes two files a year.

The circular leaves two points open. It gives no alternative threshold measure for an addressee that does not report the referenced FINREP cell at solo level, and it does not say whether the row reference tracks later FINREP releases. The contact it names for questions is macropru@cssf.lu.

What the report contains: RRE tables A to L and the six-sheet CRE form

The residential workbook

The RRE workbook on the CSSF site, the “Real estate (RE) data collection template” dated 21 April 2020 and updated on 10 May 2021, has a cover page and a single data sheet. Its tables run as follows:

  • Tables A.1 and A.2: amounts and contract numbers for new and outstanding exposures with RRE collateral, the subset with Luxembourg collateral, collateral value, collateral shortfall, and splits for amortising, non-amortising, bridge loans, owner-occupied (of which first-time buyers), buy-to-let, and variable versus fixed rate.
  • Tables B.1 to B.3: portfolio indicators (LTV, LTV_FP, LTI, LSTI, DTI, DSTI and maturity) as exposure-weighted averages, plus LTV-O, LTV_FP and LSTI-O for the buy-to-let, owner-occupied, first-time buyer, amortising, non-amortising and bridge-loan subsets.
  • Table C: new lending by maturity at origination, in bands from five years or less to more than 35 years.
  • Tables D.1 to D.3 and E.1 to E.2: LTV-O, LTV-C and LTV_FP distributions crossed with borrower income bands (up to 50K, 50K to 75K, 75K to 100K, 100K to 200K, above 200K, not available), and risk-weighted amounts by LTV band.
  • Tables F to I: new lending by LTI, DTI, LSTI and DSTI band, each crossed with income.
  • Tables J.1 and J.2: joint distributions combining LTV-O (J.1) or LTV_FP (J.2) with DSTI and maturity bands. Table K covers the buy-to-let portfolio and Table L the first-time buyer portfolio.

The ratio definitions sit in Section 3 of Circular 18/703. LTV-O is L over V at origination, LTV-C is Lc over V current, LTV-FP is L over the value of the financed property, LSTI is LS over I, DSTI is DS over I, LTI is L over I and DTI is D over I.

Section 4 then fixes each variable. L covers all loans and tranches granted to the borrower to buy the property, aggregated by borrower and by financed property, with a couple on one contract counted as one borrower. It is the granted amount in the signed contract, and the circular allows no reduction for state or personal guarantees, cash reserves or other credit risk mitigants. V is the collateral value: it may sum several securing properties, it is reduced by prior-ranking liens, and it may not be taken from the value registered in the mortgage collateral register or from the mortgage promise value. At origination, V is the lower of the transaction value and an independent appraiser’s value.

Income is where the 2026 amendment bites. I is the borrower’s recurring income net of taxes and premiums, summed for a couple, excluding other people’s income such as parents’, and computed annually.

In general, the circular gives the formula as regular employee income (excluding bonuses but including contractually agreed payments such as a 13th-month salary), plus self-employment income and rental income, minus taxes and social security contributions. Where precise rental-income information is unavailable, the reporting institution provides a best estimate and describes the methodology used. Where a significant share of the borrower’s income comes from other forms of investment, the circular permits deviation from that general formula and requires appropriate haircuts for irregular income. D is the borrower’s total debt at origination, including consumer loans, and DS and LS are annual servicing costs.

Three workbook conventions shape the data build. A percentage is entered as a number (90 for 90%), maturity as the figure only, and an empty cell is read as “data not available”. The workbook labels amounts “Amount” and counts “Number” (the number of contracts) without stating a currency unit or a scaling, and neither the circular nor the workbook sets a rounding rule. The collateral shortfall carries a sign quirk: the workbook defines each exposure’s shortfall as the minimum of 0 and C minus L, which read literally gives zero or a negative figure, and it gives no instruction to reverse the sign.

The commercial workbook

Circular 22/803 describes six sheets, and the “Form related to Circular CSSF 22/803” (updated 4 April 2022) carries them: a cover page (bank name, LEI, stock reference period, flow period, contact), a scope sheet, a stock amounts sheet with Tables A.1 to A.3 for loans, non-performing loans and loan loss provisions, a stock ratios sheet with Table B.1, and the matching flow sheets with Tables C.1 to C.3 for amounts and Table D.1 for ratios.

Every amount table splits the book two ways. Scope 1 holds loans to a legal entity to acquire income-producing real estate, or real estate the owner uses for its own business, split across five purposes: owner-used property, existing rental housing, other income-producing real estate, property under development, and property held specifically for social housing. Scope 2 holds loans to a legal entity secured by CRE, with an “of which the purpose is CRE” column. Rows break the totals down by property type (office, retail, industrial, residential, other); the loan tables (A.1 and C.1) also break them down by location (domestic prime, domestic non-prime, foreign) and into amortising and non-amortising, while the non-performing loan and provision tables carry the property-type rows only.

The ratio sheets place each indicator in one scope. LTV-C and LTV-O sit under Scope 2 and are computed at transaction level, one ratio per transaction however many collaterals support it; for the purpose rows, the circular points to loans that fall in both scopes. ICR and DSCR, current and at origination, sit under Scope 1 and are computed at property level, using gross annual rental income before taxes and operating expenses over annual interest costs (ICR) or over annual debt service including principal (DSCR). Non-performing loans follow the FINREP definition (material exposures more than 90 days past due, or a debtor unlikely to pay without realising collateral), and loan loss provisions cover all IFRS 9 stages.

Deadlines and reference dates for the April and October files

The RRE circular has the CSSF collect the data semi-annually in April and October, with reference dates of 31 December and 30 June. End-December data is due by 15 April and end-June data by 15 October, each moving to the preceding business day when the 15th falls on a holiday.

Circular 22/803 sets the same two submission dates and spells out the windows. The 15 April file carries all new CRE exposures issued between 1 July and 31 December of the previous year and all outstanding exposures at 31 December. The 15 October file carries new exposures issued between 1 January and 30 June and outstanding exposures at 30 June. Each half-year is due three and a half months after it closes.

The CRE threshold runs on its own clock. The circular’s key-information table places the computation in December of the year before submission, and Section 2.2 ties year Y to the FINREP figure at 31 December of year Y-1. Both files in a given year follow that single test. A lender whose collateralised NFC book passes EUR 250 million in March therefore files blank reports in April and October of that year, and full reports from the following April if the figure at 31 December is above the line.

What counts as new lending in the half-year differs between the two returns. In RRE, a loan granted earlier and then modified stays out of new lending, and a loan restructured because of unlikeliness to pay is treated as a modified existing loan: excluded from flows, included in stock. A loan taken over from another lender “can be considered” a new exposure. In CRE, renegotiated loans enter new production if the lender considers them new loans, and a loan repurchased from another lender “must be considered” new.

On first reference dates the sources are thin. The consolidated RRE circular does not restate the first reference date of the collection, and Circular 22/803 became applicable on publication in March 2022 without naming its first reporting period.

Submission channels: eDesk and S3 for RRE and CRE, with E-file and SOFiE still named in Circular 22/803

Since Circular 26/908, the RRE standards for transmission say that starting from 2024 lenders may submit through one of two methods: a dedicated eDesk approach in the eDesk Portal, or the API solution based on a structured exchange file in JSON format sent over the S3 (“Simple Storage Service”) protocol. The same amendment struck out the sentence naming E-file and SOFiE, the reminder to submit the latest template version, and the whole naming block for ESPREP-ENNNN-YYYY-MM-RES. Questions on the circular go to macropru@cssf.lu, and technical eDesk questions to edesk@cssf.lu. The same two channels appear across other CSSF returns; our note on the move of PI, EMI and CASP prudential reporting to eDesk covers that shift for payment and crypto firms.

The circular does not state a JSON schema version, and neither real estate circular mentions XBRL or a DPM taxonomy. The technical specification for the S3 route sits outside the circular, and the sources reviewed here do not reproduce it.

The CSSF’s news release of 5 April 2024 on direct transmission of procedures lists the “Semi-annual data collection on lending indicators related to commercial real estate”, alongside the RRE return, among the procedures available through both eDesk and the API (S3), although Circular 22/803 itself has not been amended on this point. Section 2.4 of the circular still requires the filled-in template to reach the CSSF on the submission date through E-file or SOFiE, named ESPREP-ENNNN-YYYY-MM-CRE. In that code, ESP is the reporting type for special enquiries, REP the direction (report), E the entity type (B for banks), NNNN the bank’s identification number from 0001 to 9999, YYYY and MM the cut-off year and month of the data, and CRE the table reference. The deleted RRE name followed the same pattern with RES as the table reference.

The consequence for a file-generation job is direct. An RRE extract still stamped ESPREP-…-RES follows a naming rule withdrawn in March 2026, while a CRE file sent through E-file or SOFiE still takes the ESPREP-…-CRE name that Circular 22/803 prints. The sources reviewed here do not say whether that name also applies to a CRE file submitted through eDesk or S3. Neither circular describes a resubmission or correction procedure.

Validation: the checks written into the templates

Neither Circular 18/703 nor Circular 22/803 sets out a validation-rule catalogue, plausibility-rule list or table of rejection causes. Any additional workbook, eDesk or transmission-channel validations should be checked in the current CSSF technical materials.

The RRE workbook states its own reconciliation rules in a note on the data sheet. The first line of Table A (all exposures with RRE collateral, wherever located) and the collateral value line are wider than the survey. The totals of Tables C, D and F to J must add up to the second line of Table A, the exposures whose RRE collateral is in Luxembourg, which is the survey’s scope. Table K must add up to the buy-to-let line of Table A and Table L to the first-time buyer line. The cover page asks lenders not to change the template’s structure, character limits or formatting, and to report a number wherever possible.

The CRE workbook builds its consistency into the layout. The rental housing and social housing columns take amounts only on the residential property-type row and the location rows, which ties those purposes to residential property. The amortising split is collected only for total Scope 1 and total Scope 2. LTV cells exist only under Scope 2, ICR and DSCR only under Scope 1, and each ratio sits beside the amount of exposures on which it was computed.

Where a file goes wrong on substance, the circulars give the reference point. The texts rule out, among other things:

  • the mortgage register value or the mortgage promise value as a source for V, in both returns;
  • any reduction of L for guarantees or other credit risk mitigants, and any adjustment of V for them, in both returns;
  • costs and fees in L and V, and loan subsidies in L, in the CRE return;
  • a long-term value in place of the value at origination, in both returns;
  • one LTV per collateral in CRE, where the circular asks for one per transaction.

Caveats and interactions: the RRE and CRE boundary, AnaCredit and Regulation 20-08

Borrower type is one boundary, not the full routing rule. Circular 18/703 covers loans taken to purchase residential real estate in Luxembourg that are secured by real-estate collateral located in Luxembourg, and excludes loans to legal entities, including SCIs and SOPARFIs.

Circular 22/803 defines its two CRE scopes for loans to legal entities: Scope 1 covers loans with a CRE purpose and Scope 2 loans secured by CRE collateral. It also states that a letting loan requested by a natural person is reported in the RRE template. Classification therefore requires borrower type together with the applicable property-purpose and collateral conditions. A legal-entity loan can consequently fall within the CRE collection even where the underlying property type is residential.

Location splits the two as well. The RRE survey scope requires both the purchased property and the collateral to be in Luxembourg. CRE property can be in Luxembourg or abroad, and the foreign bucket exists to capture it. For the domestic split, the circular’s examples of prime locations include the Central Business District or Kirchberg for offices and the Findel area for logistics.

AnaCredit overlaps with the commercial side by design: Circular 18/703 notes that real estate credit to legal entities falls under the CRE reporting and under AnaCredit. They remain separate returns with separate definitions, and the circulars do not reconcile them. Losses sit elsewhere again: the CRR return on losses stemming from lending collateralised by immovable property (C 15.00, Article 430a CRR), which the CSSF’s reporting requirements manual lists as annual from the December 2021 reference date. Our CRR Article 430a guide covers that return.

The residential collection also serves CSSF Regulation No 20-08, which is why LTV_FP exists. Circular 21/772 inserted a value “in line with CSSF Regulation No 20-08”, computed on the financed (purchased) property at the time of the loan arrangement. It differs from V only where the financed property is not the collateral, or not the only collateral. The CSSF updated its technical FAQ on Regulation 20-08 on 25 March 2026, the same day as Circular 26/908. For the wider Luxembourg property-lending risk picture, see our summary of the BCL Financial Stability Review 2026.

Valuation discipline for V current comes from outside the circulars. Circular 18/703 points to Articles 208(3) and 229 CRR and to Circular CSSF 22/824, which applies the EBA Guidelines on loan origination and monitoring (EBA/GL/2020/06), and it requires independence from the credit decision in the spirit of Article 208(3)(b) CRR. An in-house current value may not be produced by commercial agents, and the lender documents its method in internal procedures. Circular 22/803 relies on Article 208(3) CRR for commercial collateral: revaluation at least once a year, and more often where the market has been subject to significant negative changes or there are signs of a significant decline in the value of the individual collateral.

On proportionality, the residential circular itself contains no waiver, national discretion or transitional provision. The CSSF’s Questions and Answers on Circular 18/703 supply two devices: the EUR 10 million exclusion, and permission to leave employees’ loans out of the income-related tables where the bank gives the CSSF written assurance that their share of total new loans is marginal and that excluding them does not significantly bias the income buckets or the ratio levels. Employees’ loans stay in every table that does not use income. The commercial circular’s only proportionality device is the threshold with its blank report.

Changes from Circular 18/703 in 2018 to Circular 26/908 in 2026

  • 17 December 2018: Circular 18/703 introduces the semi-annual RRE return, with the template annexed to the circular.
  • 19 February 2020: Circular 20/737 moves the template out of the annex and onto the CSSF website. Later template changes that leave the definitions untouched are published there, with notice to reporting institutions.
  • 7 May 2021: Circular 21/772 updates the template, folds in clarifications already published in the related FAQ, and adds the data needed to monitor Regulation 20-08, including the V_FP value and LTV-FP ratio. The workbook on the CSSF site is dated 10 May 2021.
  • 18 March 2022: Circular 22/803 launches the semi-annual CRE collection. Its form was updated on 4 April 2022.
  • 5 April 2024: a CSSF news release on direct transmission of procedures lists both the RRE return and the CRE collection among the procedures available through eDesk and the API (S3).
  • 25 March 2026: Circular 26/908 amends Circular 18/703, applicable from its publication date.

Circular 26/908 summarises its own changes as mainly the treatment of rental income in borrower income, updated regulatory references, and revised reporting processes and submission channels. The track-changes annex shows the detail:

  • rental income added to the disposable income formula, with the best-estimate rule and a described method;
  • the reference to EBA/GL/2015/11 and to Article L. 226-12 of the Law of 23 December 2016 transposing the Mortgage Credit Directive replaced by EBA/GL/2020/06 and Circular CSSF 22/824;
  • appraiser values at origination and V current tied to Articles 208(3) and 229 CRR and Circular 22/824;
  • VEFA purchases valued at the selling price in the notarial deed or the sale contract, with the VAT rate “applicable to the property concerned” replacing a fixed 17%;
  • the LTV-C numerator corrected from L to Lc, with an explicit definition of Lc as the outstanding amount at the reporting date;
  • eDesk and S3 replacing E-file, SOFiE and the ESPREP-…-RES file name.

The CSSF’s current Circular 18/703 page shows amendments through Circular 26/908. The current Circular 22/803 page continues to publish the 2022 circular without an amending circular, and its E-file and SOFiE wording differs from the amended RRE transmission rules.

Frequently Asked Questions

A borrower buys a Luxembourg flat but secures the loan on a house in France. Does the loan enter the RRE file?

Only partly. The workbook’s first line of Table A takes every exposure with RRE collateral, wherever the collateral is located, so the loan appears there. The survey scope requires the purchased property and the collateral to be in Luxembourg, so the loan stays out of the Luxembourg-collateral line and out of the tables that must reconcile to it.

A couple takes a new mortgage and a bridge loan while their old home is on the market. How many L values does that produce?

The circular separates loans by the property they finance, so the bridge loan and the purchase loan are split by property and each is aggregated for the couple as one borrower. For the bridge loan, LS contains interest payments only. The circular adds that bridge loans should in general not exceed 18 months and be non-renewable, extending to 24 months for new constructions.

Can V current come from a house-price index instead of a revaluation of each property?

Yes, within limits. The circular accepts a valuation model or an RRE value index that is granular by municipality and property type (new, old, apartment, house). Where such an index is not available, the circular allows an RRE value index that is still sufficiently granular by geographical location and property type, after a suitably chosen mark-down to account for the property’s depreciation. Either way, the valuation must be independent of the credit decision.

Is the collateral value in Table A the same V used in the LTV ratios?

No. The workbook’s “Useful definitions” tie the Table A collateral value to paragraphs 171 to 174 of Annex V to Implementing Regulation (EU) No 680/2014, count both collateral received and financial guarantees received, apply the same definition to the collateral shortfall, and state that this collateral value is different from the V requested for an LTV ratio. That reference is historical: Implementing Regulation (EU) No 680/2014 was repealed by Implementing Regulation (EU) 2021/451, and Implementing Regulation (EU) 2024/3117 replaced most of that reporting framework, although, as amended by Implementing Regulation (EU) 2025/2475, Implementing Regulation (EU) 2021/451 is not fully repealed until 31 December 2026. The current workbook still cites Implementing Regulation (EU) No 680/2014, and the primary sources reviewed do not say how that reference maps to the successor FINREP instructions, so the mapping is a point to confirm with the CSSF before implementation.

A borrower has a two-year capital moratorium at the start of the loan. Which loan service goes into LSTI?

The circular uses the amount that will fall due once repayment starts. A pure interest-only loan carries interest payments only, a bullet loan with no payments during its life produces no LS or DS at all, and contributions to a savings plan contracted for the purchase or renovation count as loan service.

A group reports RRE at consolidated level. Do Luxembourg mortgages booked in a consolidated subsidiary belong in the file?

The workbook asks for the highest consolidation level available and makes the collection exhaustive, which I read as bringing in in-scope loans booked anywhere in the consolidated perimeter. The circular itself does not address the case, so a lender taking that reading has no text to point to beyond the cover-page instruction.

Key Takeaways

  • Route each loan using borrower type together with the applicable property-purpose and collateral tests: RRE excludes legal entities and applies to loans financing residential real estate in Luxembourg that are secured by real-estate collateral in Luxembourg; CRE Scope 1 and Scope 2 cover loans to legal entities based respectively on CRE purpose or CRE collateral.
  • Read FINREP Table 18, row 0140, column 010 at every 31 December: it fixes blank or full CRE files for both of the next year’s submissions.
  • Rebuild the RRE income variable with rental income, a best estimate where data is missing, and a written method, as Circular 26/908 requires.
  • Route RRE through eDesk or the S3 JSON API and retire any job that still generates an ESPREP-…-RES file.
  • Choose the CRE channel deliberately: Circular 22/803 still names E-file or SOFiE and the ESPREP-ENNNN-YYYY-MM-CRE file name, while the CSSF’s news release of 5 April 2024 lists the CRE collection among the procedures available through eDesk and the API (S3).
  • Reconcile RRE Tables C, D and F to J to the Luxembourg-collateral line of Table A before each file leaves.
  • Run CRE at the lowest solo level without foreign branches and RRE at the highest consolidation level available.

Sources and References

Preparing the next ESPREP-RES and CRE files

The next file is always one of two: the 15 April return on 31 December data or the 15 October return on 30 June data. Before either leaves, three artifacts decide whether it is right. The first is a loan-level mapping that places every real estate exposure in RRE, CRE or neither, by borrower type together with the property-purpose, collateral and location tests each circular applies. The second is the RRE income recalculation with rental income under Circular 26/908. The third is the 31 December FINREP Table 18 figure that settles whether this year’s CRE files are full or blank.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

Similar Posts

  • Non-Maturity Deposit Stability: What BCBS Working Paper 47 Signals

    Updated September 2026In this guideWhat the Committee actually published on 20 February 2026The 2023 question behind the reviewWhere deposit behaviour is priced into the LCRThe NSFR encodes the same split at a one-year horizonWhy a literature review lands on your models, not your ratiosPillar 2 and the supervisory review of deposit assumptionsWhat to check in…

  • MMF Weekly Liquid Assets: What the CSSF Consultation Means for Luxembourg Managers

    Updated July 2026In this guideWhat the CSSF published on 8 June 2026The statutory MMF weekly liquid assets minimums the guidance leaves untouchedThe notification trigger most managers will need to wire inWhat the resilience levels do not meanHow this connects to stress testing under Article 28What Luxembourg managers should review before 3 August 2026Frequently Asked QuestionsRelated…

  • SRB Resolution Reporting: RESOL 1 and RESOL 2 Under the New ITS

    For the 2026 collection cycle, the Single Resolution Board is retiring the resolution templates that banks have filed for the best part of a decade. From this cycle, the SRB’s annual resolution-planning collection uses two reporting modules, RESOL 1 and RESOL 2, built on the revised Implementing Technical Standards in Commission Implementing Regulation (EU) 2025/2303….

  • EBA MREL Dashboard Q4 2025: How Resolution Reporting Teams Should Read the 25-29% RWA Benchmarks

    Updated September 2026In this guideWhat the EBA MREL dashboard actually measuresExternal versus internal MREL: do not compare the wrong numberWhere the dashboard data comes from in your reporting stackTwo reporting channels, two sets of deadlinesHow to use the benchmark data without misreading itFrequently Asked QuestionsRelated ArticlesKey TakeawaysSources and ReferencesReading the dashboard as a control, not…

  • EuReCA Reporting: CSSF Names AMLA in Joint Controllership Update

    On 11 September 2026, the Commission de Surveillance du Secteur Financier (CSSF) reissued its statement on the EuReCA joint controllership arrangement, and the edit is narrow on the page but material underneath it: every reference to the European Banking Authority (EBA) is now a reference to the Authority for Anti-Money Laundering and Countering the Financing…

  • Pillar 3 Disclosure Requirements for Luxembourg Banks – A Practical Guide

    Updated July 2026In this guideWhat Pillar 3 Is and Why It ExistsLegal BasisWho Must DiscloseWhat Gets Disclosed: The Template FrameworkDisclosure Frequencies at a GlanceFormat and Publication RequirementsESG Disclosures Under Article 449aLuxembourg-Specific ImplementationCommon Errors and Supervisory FindingsFrequently Asked QuestionsKey TakeawaysRelated ArticlesSources and ReferencesCOREP and FINREP go to the supervisor. Pillar 3 goes to the public. That…