Circular CSSF-CPDI 26/52: Covered Deposits Survey Due 16 November

On 2 October 2026 the CSSF’s Conseil de protection des déposants et des investisseurs (CPDI), Luxembourg’s designated authority for deposit guarantees, published Circular CSSF-CPDI 26/52. It launches the quarterly survey of covered deposits held on 30 September 2026 and gives every member of the Fonds de garantie des dépôts Luxembourg (FGDL) until 16 November 2026 to transmit the figures. An institution with nothing to report still has to file: the circular makes the transmission mandatory with zeros in the relevant fields.

Paragraph 2 of the circular says that the content, the terms of the survey and the annexed specifications are unchanged from the previous quarterly survey. Only the reference date and the deadline move. The stakes sit behind the numbers. The circular states that the data “also constitutes the basis to determine the contribution to the Resolution Fund”, and it requires a named member of the authorised management to review and approve the report before it reaches the CSSF.

For the reporting team the job is a reconciliation built on the amended Law of 18 December 2015 on the failure of credit institutions and certain investment firms (the Law of 2015): total deposits, eligible deposits after the Article 172 exclusions, a look-through on omnibus and fiduciary accounts, claim counts per depositor, and a chain of arithmetic identities written into the annex.

Related reading: Deposit Guarantee Scheme Reporting in Luxembourg: FGDL Membership, SCV Files, and the Covered Deposits Survey

Circular CSSF-CPDI 26/52 dates and the 2026 survey cycle

The surveys since the 2025 year-end have run on one template. Each circular names a reference date, a submission deadline and an annex of field specifications that has not changed between quarters. The table below sets the current survey against its three predecessors.

Three details matter for planning. The circular gives a date with no cut-off time. The deadlines are calendar dates: the CPDI set the first-quarter deadline on Saturday 16 May 2026, while 16 November 2026 falls on a Monday. And the year-end survey runs to a much shorter window. Circular CSSF-CPDI 25/49, dated 24 December 2025, gave members 22 days, and it attached uses to the 31 December figures that the quarterly circulars do not mention: the annual FGDL contribution calculation and a transmission to the Single Resolution Board (SRB) by 30 January 2026.

The year-end circular also asked for more data. Paragraph 5 of Circular CSSF-CPDI 25/49 required the legal-entity figure and, separately, a figure for each branch in another Member State, with an eDesk report per branch. Circular CSSF-CPDI 26/52 asks only for the legal-entity figure, which includes the EEA branches.

Who sits in the FGDL survey population

The circular is addressed to the members of the FGDL and lists three kinds of institution:

• credit institutions incorporated under Luxembourg law;
• POST Luxembourg, for its provision of postal financial services only;
• Luxembourg branches of credit institutions with their head office in a third country.

These are the members that Article 166(1) of the Law of 2015 brings into the FGDL, with third-country branches included “subject to Article 184”. That qualifier matters. Article 184 has the CSSF check whether a third-country branch already enjoys protection equivalent to the Luxembourg regime, and Article 184(3) sets information duties for third-country branches that are not FGDL members. For a third-country branch, FGDL membership itself is what puts it in the survey population.

Luxembourg branches of banks headquartered in another EEA state are absent from the addressee list. Their depositors are protected by the home-state scheme, and Article 183(1) of the Law of 2015 has the FGDL repay those depositors on behalf of the home DGS when instructed and funded. Investment firms fall under a separate scheme, the Système d’indemnisation des investisseurs Luxembourg (SIIL) created by Article 156, which also counts credit institutions among its members under Circular CSSF-CPDI 16/02.

Branches abroad run the other way. A Luxembourg bank reports at legal-entity level, “comprising data from branches located within other Member States”. Footnote 1 of the circular extends “Member States” to EEA contracting parties under Article 153(2) of the Law of 2015 and repeats that deposits held at branches in the United Kingdom must not be reported, because FGDL coverage of those deposits ceased on 1 January 2021. A Luxembourg bank with a branch in Dublin and another in London therefore includes the Dublin deposits and leaves the London deposits out of every field.

The annex retains three institution codes. Institutions governed by Luxembourg law use “Credit institutions governed by Luxembourg law, as well as POST Luxembourg”, while third-country branches use “Luxembourg branches of credit institutions having their registered office in a third country”. The unchanged annex also contains the code “EEA branch of a Luxembourg credit institution”, but Circular CSSF-CPDI 26/52 requests the September data only at legal-entity level, comprising branches in other Member States; it does not request a separate return for each EEA branch. Separate branch-level reports were expressly required for the 31 December 2025 survey under Circular CSSF-CPDI 25/49.

From field 0100 to field 0400: the annex arithmetic

The annex to Circular CSSF-CPDI 26/52 builds the survey as a funnel. It starts from every deposit in the Article 163 sense, removes what is not eligible, splits the remainder by depositor type and by the EUR 100,000 threshold, then derives the covered amount and the excess. Amounts are in euro with two decimals (format 20,2N); claim counts are whole numbers (format 10N). Balances in other currencies are converted at the ECB exchange rate published in the Official Journal and applicable at the end of the quarter.

Fields 0220 and 0225 need the closest reading. The annex asks for “the sum of all credit balances” of each depositor whose eligible total exceeds EUR 100,000, so the whole balance goes in. The cap arrives two steps later, in 0320 and 0325, as a head count multiplied by EUR 100,000. Take a natural person with EUR 240,000 of eligible deposits: 0220 rises by 240,000, 0245 by one, 0320 by 100,000, and the remaining 140,000 surfaces in 0400. A mapping that loads only the excess, or only the covered slice, into 0220 leaves 0201 short of the eligible balances the institution actually holds, and the clipping figure stops meaning anything.

Two smaller points. Field 0100 includes accrued interest “even when it is not yet due”, which the annex ties to Article 171(5) of the Law of 2015. And the annex refers to the same fields with both four-digit and three-digit identifiers (“fields 0210, 215, 220 and 0225”, “fields 230 to 250”); I read the short forms as the four-digit fields 0215, 0220 and 0230 to 0250. Field 0400 has no instruction beyond the subtraction. It is a residual, and it only reconciles if every field above it does.

Eligibility: what field 0201 strips out

Field 0201 applies the exclusions in Article 172(1) of the Law of 2015. The list is long; three layers carry Luxembourg-specific detail.

The first is the financial-institution exclusion as the CPDI applies it. Circular CSSF-CPDI 16/02, as amended by Circular CSSF-CPDI 23/35, assimilates Soparfis, family wealth management companies (SPF), securitisation undertakings, offshore investment vehicles and companies or foundations set up for estate planning or wealth management to financial institutions under Article 4(1), point (26), of the CRR. Their deposits are excluded. Two carve-backs apply: “pure industrial holding companies”, and non-profit foundations governed by the amended Law of 21 April 1928.

Paragraph 5 of Circular CSSF-CPDI 16/02 also excludes deposits made by insurers in the context of unit-linked life policies or insurance wrappers, and it states that the look-through in Article 174 applies neither to these assimilated entities nor to collective investment undertakings. The survey annex adds that “the size of a company is no longer a reason for exclusion”.

The second is public authorities. Circular CSSF-CPDI 18/14 reads the Article 172(1), point 10, exclusion narrowly, on the principle that exceptions are interpreted strictly. For deposit guarantee purposes, public authorities are the counterparties classified by the Banque centrale du Luxembourg (BCL) as central government (sector code 11000) or other general government (sector code 12000). The counterparty’s BCL sector code, rather than its name, decides the treatment.

The third layer catches accounts that are not deposits for this purpose at all. The circular and the annex both state that accounts denominated in units of precious metals, such as gold (XAU) or silver (XAG), and accounts denominated in virtual currencies, such as Bitcoin or Ether, are not eligible deposits and “should not be reported in the deposit data collection survey”. That wording takes them out of field 0100 as well. The treatment differs from deposits that other credit institutions make on their own behalf and for their own account, which are excluded from eligibility under Article 172(1), point 1, yet stay in total deposits: the annex names “deposits made by credit institutions and central banks” as part of field 0115. A team that books an XAU account into 0115 as a non-eligible deposit overstates total deposits; one that drops interbank balances from 0100 understates them.

Omnibus, fiduciary and trust accounts: the look-through rules

For the survey, “omnibus accounts” is a wide label. The annex groups omnibus accounts, accounts opened by fiduciaries or trusts, third-party accounts, sub-accounts and segregated accounts under it, and assimilates accounts held for third parties by account holders within the Law of 27 July 2003 concerning trust and fiduciary contracts.

Article 174 of the Law of 2015 covers the person absolutely entitled to the sums, provided that person has been or can be identified before the guarantee is triggered. Paragraph 4bis of Circular CSSF-CPDI 16/02 tightens the identification standard: persons absolutely entitled to sums in omnibus accounts are treated as beneficial owners under the Law of 12 November 2004 on the fight against money laundering and terrorist financing, identified through simplified or enhanced due diligence. Any lack of identifiability has to be justified and documented, and the CPDI may ask for the supporting documents under Article 168. The annex is blunt about the consequence: an omnibus account whose persons absolutely entitled are not identified or identifiable is not eligible.

Where the look-through works, three fields carry it. Field 0226 holds the eligible amount in omnibus-type accounts, already apportioned across 0210 to 0225. Field 0255 counts the persons absolutely entitled. Field 0330 holds the covered part, capped at 0255 times EUR 100,000.

The natural-person and legal-person split runs against intuition. The annex requires the balance owed to each beneficiary to be reported “depending on the legal status of the holder of the account without regard to the legal status of the persons absolutely entitled”. A Luxembourg fiduciary company holding funds for 300 private individuals is a legal person, so every one of those shares lands in 0215 or 0225, and the claims in 0240 or 0250, even though each beneficiary is a natural person.

The fallback deserves a careful reading. Circular CSSF-CPDI 26/52 says that, absent “a reliable and up to-date estimate” of the number of entitled persons and their amounts, members report the total amount of omnibus accounts opened in their books. Paragraph 4ter of Circular CSSF-CPDI 16/02, which the survey circular tells members to apply, frames that same fallback as one for “exceptional circumstances” and pairs it with a duty to take reasonable measures to obtain the beneficiary information regularly. My reading is that the fallback covers a gap that the institution has tried to close, and does not give an institution a standing option to skip the look-through.

One question the annex leaves open: whether a beneficiary’s omnibus share is added to deposits the same person holds directly with the bank before the EUR 100,000 test. Article 163, point 5, treats persons absolutely entitled under Article 174 as depositors, and Article 171(1) applies the limit to “all the deposits of a depositor in the same member institution”, which points toward aggregation. The annex itself does not say.

Survey conventions that differ from the payout rules

Several annex instructions depart from the rules the FGDL would apply in an actual payout. Each produces a figure that cannot be reused unchanged in a payout file, and the reverse is true as well.

Temporary high balances come first. Article 171(2) of the Law of 2015 protects certain deposits above EUR 100,000, up to EUR 2,500,000 for twelve months: deposits resulting from real estate transactions relating to private residential properties, as well as compensation received following claims incurred in respect of a private residential property; deposits that serve social purposes and are linked to particular life events of a depositor such as marriage, divorce, retirement, dismissal, redundancy, invalidity or death; and deposits based on insurance benefits or compensation for criminal injuries or wrongful conviction. The survey ignores that uplift. The annex treats such balances “as normal deposits with a limited guaranteed amount of EUR 100,000”, and the explanation for field 0300 repeats the cap.

Set-off is the second. Article 175 requires a payout to take account of a depositor’s liabilities that have fallen due on or before the determination or decision that makes deposits unavailable, to the extent set-off is possible under the statutory and contractual provisions governing the deposit. The annex disapplies Article 175 for the survey: only credit balances count, and a depositor with a debit balance and no credit balance is left out of the claim counts in fields 0230 to 0250.

Currency conversion is the third. The survey uses the ECB rate applicable at the end of the quarter. A payout under Article 176(5) uses the ECB rate in force at the time of the determination or decision that makes deposits unavailable.

Joint accounts follow the payout logic more closely. Field 0230 counts co-holders of joint accounts as separate claims, and Article 173(1) splits a joint account equally among depositors in the absence of special provisions. Partnerships, associations or similar groupings without legal personality are treated as a single depositor under Article 173(2), and the annex tells members to report them as legal persons.

The survey and the SCV file: one ledger, two rule sets

FGDL members already run a second deposit dataset: the Single Customer View (SCV) file required by Article 169 of the Law of 2015 and specified by Circular CSSF 13/555 as amended by Circular CSSF-CPDI 23/36. Both datasets draw on the same customer ledger. They answer different questions, and a reconciliation between them will show gaps by design.

The SCV file is a payout tool. Circular CSSF 13/555 requires a semicolon-separated CSV file that the bank can deliver before midnight of the third working day after the CPDI requests it. Paragraph 7 of that circular has a failing member apply and book set-off of due debts under Article 175 before generating the file, so SCV balances are net (or carry both legs for the CPDI to net where booking is not possible). The survey forbids set-off.

Omnibus accounts diverge too, and Circular CSSF 13/555 says so itself. Section D, headed “Link with the quarterly survey on the amount of covered deposits”, states that the survey’s covered deposits “shall account for the entitlement of each beneficiary in so-called omnibus accounts whereas the SCV file merely reports the total balance of such omnibus accounts”. The same section adds that the SCV circular “in principle” does not interfere with the quarterly data collection.

My working assumption is that a control comparing SCV totals with survey totals is still useful, provided its tolerance allows for these two differences. A gap that neither set-off nor the omnibus look-through explains is the one worth investigating.

Where the 30 September figures go after submission

Covered deposits drive two funding mechanisms in opposite directions. In the FGDL formula they are the base. In the resolution-fund formulas they are deducted from the base.

On the FGDL side, Article 179(1) of the Law of 2015 sets the target level of the fund’s available financial means at 0.8% of the covered deposits of member institutions, raised through contributions paid at least annually. Once that target is reached, Article 180(1) requires members to keep contributing to a separate buffer of additional financial means of a further 0.8% of covered deposits within eight years. Article 182(1) bases contributions on “the amount of covered deposits and the degree of risk incurred by the respective member institution”.

The current calculation method is Circular CSSF-CPDI 25/48 of 13 November 2025, which repealed Circulars CSSF-CPDI 20/21 and 23/34. The year-end survey is the one tied to those annual contributions: Circular CSSF-CPDI 25/49 said its 31 December 2025 data would determine the 2026 contributions under Articles 179 and 180. Since an amendment by the Law of 5 May 2026, Article 179(4) also phases in the contributions of a new FGDL member, one-third per year over three years for the target-level contributions and one-eighth over eight years for the buffer.

On the resolution side, Circular CSSF-CPDI 26/52 refers to “the Resolution Fund” without naming which one. Two mechanisms use covered deposits:

• The Single Resolution Fund (SRF). Circular CSSF-CPDI 25/49 stated that, pursuant to Article 16(1) of Commission Delegated Regulation (EU) 2015/63, the average of the quarterly covered-deposit amounts would be transmitted to the SRB by 30 January 2026 to determine the SRF’s annual target level. Under Article 70(2) of Regulation (EU) No 806/2014, the flat part of each institution’s contribution is pro rata to its liabilities excluding own funds and covered deposits. Circular CSSF-CODERES 26/22 records that the SRB will verify in the first quarter of 2027 whether the SRF’s available financial means equal at least 1% of covered deposits in the Banking Union before deciding whether to collect 2027 contributions. Our article on the CSSF-CODERES 26/22 SRF data reporting form covers that filing.
• The Fonds de résolution Luxembourg (FRL). Article 107(1) of the Law of 2015 sets its target at no less than 1% of the covered deposits of institutions authorised under the Law of 5 April 1993, Article 107(4) exempts institutions that pay into the SRF, and Article 108(2) allocates contributions pro rata to liabilities excluding own funds, less covered deposits. Circular CSSF-CODERES 26/22 notes that Luxembourg branches of institutions with their head office outside the EU fall under the FRL.

The averaging has a practical consequence. A misstatement at 30 September does not disappear when the 31 December figure is right, because the SRB input is described as an average of the quarterly amounts.

Submission through eDesk or S3, validation and the approval step

The circular offers two channels: the CSSF eDesk platform, or a structured file sent through the S3 (“simple storage service”) protocol. A user guide on eDesk covers completing, validating and submitting what the CSSF calls the “DCOR Quarterly Reporting”.

The S3 route has its own set-up, described in the CSSF’s technical guidance on transmitting reports via the S3 application programming interface (version 1.0, published 27 July 2023). Enrolment runs through eDesk: the entity’s “Advanced User” grants the “IT Expert” role, and the IT Expert creates, views and revokes access keys in the eDesk IT management console. The guidance states that S3 here refers only to the object-storage protocol and does not rely on any commercial cloud provider. Each entity’s bucket has a “submission” folder for reporting files and a “feedback” folder for the CSSF’s responses, and the secret key can be viewed only once. One detail is easy to miss: the CSSF cleans files in both folders 20 days after creation, so the feedback file is the institution’s own record to keep.

Validation and corrections follow a two-step rule. If eDesk validation rules detect errors, the member has to resubmit a corrected report. Paragraph 5 of the circular covers everything after that: for errors or omissions in transmitted data, including a resubmission after the 16 November deadline, the institution contacts the CPDI at cpdi@cssf.lu as soon as it notices the problem.

The approval step is personal. Paragraph 6 requires “a member of the authorised management, in this case the member in charge of the membership of the FGDL” under section C of Circular CSSF 13/555 to review and approve the report before transmission. Paragraph 13 of that circular has the authorised management designate at least one of its members for FGDL membership and transmit the name, and any later change, to both the CSSF and the FGDL. The survey circular is silent on how the approval should be evidenced. A separate obligation, paragraph 12 of Circular CSSF 13/555, has all members of the authorised management sign an annual written compliance confirmation on the SCV scheme and send it with the annual accounts.

Directive (EU) 2026/804 and the perimeter this survey measures

The deposit guarantee leg of the EU crisis management and deposit insurance (CMDI) package, Directive (EU) 2026/804 of 30 March 2026, was published in the Official Journal on 20 April 2026. It amends Directive 2014/49/EU (DGSD). Member States have to adopt and publish the transposing measures by 11 May 2028 and apply them from that date, with the preventive-measure provisions applying from 11 May 2029. Our explainer on the Directive (EU) 2026/804 DGSD amendment covers the full text, and our note on the CMDI package’s Official Journal publication places it alongside the BRRD and SRMR amendments.

Four amendments touch the perimeter that fields 0201 to 0330 measure, once Luxembourg transposes them:

• The public-authority exclusion narrows to deposits by central or state governments as defined in points 2.114 and 2.115 of Annex A to Regulation (EU) No 549/2013, with the exception of non-profit institutions they control. Circular CSSF-CPDI 18/14 currently also excludes BCL code 12000, other general government.
• Temporary high balances get a harmonised protection of at least EUR 500,000 for six months, supplementary to the EUR 100,000 level, with a maximum of EUR 2,500,000 for residential real estate transactions.
• A new Article 8b covers client funds deposits placed by financial institutions on segregated accounts for identified or identifiable eligible clients, applying the coverage level to each client without aggregating that client’s other deposits at the same bank.
• A new exclusion covers deposits meeting the conditions in Article 45b(1a), points (a) to (d), of Directive 2014/59/EU, including those with a residual maturity of less than one year.

None of this reaches the 30 September 2026 survey. Circular CSSF-CPDI 26/52 measures the perimeter of the Law of 2015 as it stands, and it states that nothing in the survey has changed. Whether the CPDI will add fields, for example a separate client-funds line, or revisit the EUR 100,000 survey cap on temporary high balances once Article 171(2) is rewritten, is not addressed in Circular CSSF-CPDI 26/52 or its 2026 predecessors.

Frequently Asked Questions

Our bank only takes deposits from other banks and from investment funds. Is an all-zero return correct?

Field 0100 still carries those balances. They are deposits in the Article 163 sense, so they belong in 0100 and 0115; the annex names deposits made by credit institutions and central banks as part of 0115. Eligibility removes them under Article 172(1), points 1 and 8, so fields 0201 onwards stay at zero for the funds’ deposits and for deposits the banks make on their own behalf and for their own account. Point 1 applies subject to Article 174, and paragraph 4 of Circular CSSF-CPDI 16/02 extends the look-through to omnibus accounts that credit institutions use for their customers’ money, fiduciary arrangements included: where those customers are eligible and identified or identifiable, their shares count in 0201 under the legal-person fields and in 0226, 0255 and 0330. The zero-filled nil return described in the circular applies only where no amount exists at all.

Two spouses hold a joint account with EUR 180,000, and one of them also has a EUR 40,000 savings account with us. How does that map?

Each co-holder is a claim, and Article 173(1) splits the joint balance equally absent special provisions, so each spouse has EUR 90,000. Because the limit applies to all deposits of a depositor in the same institution, the spouse with the savings account totals EUR 130,000 and goes into 0220 and 0245; the other spouse’s EUR 90,000 goes into 0210 and 0235. Covered deposits come to EUR 190,000 (90,000 plus one times 100,000), and clipping is EUR 30,000.

A client holds EUR 150,000 on a current account and owes EUR 60,000 on an overdraft that has fallen due. Which figure do we report?

The survey uses the credit balance only: EUR 150,000 in 0220, one claim in 0245, EUR 100,000 in 0320 and EUR 50,000 of clipping. The overdraft is ignored because the annex disapplies Article 175. In an SCV file generated under Circular CSSF 13/555, the same client would appear net of the due debt where the contract allows set-off.

We found an error in our 30 June submission under Circular CSSF-CPDI 26/51 while preparing September. Can the September return absorb the correction?

Each circular fixes its own reference date, and paragraph 5 of Circular 26/51 already requires contacting the CPDI at cpdi@cssf.lu as soon as an error is noticed, including where a resubmission comes after the deadline. Folding a June correction into the September figures would misstate both quarters, and the 2025 year-end circular described the SRB input as an average of the quarterly covered-deposit amounts.

Does the Luxembourg branch of a bank headquartered outside the EU file this survey?

It files if it is an FGDL member, using the third-country branch code. Article 166(1) of the Law of 2015 makes such branches members subject to Article 184, under which the CSSF checks whether home-country protection is equivalent; Article 184(3) gives branches that are not FGDL members information duties toward the CPDI and depositors instead. Looking further ahead, Article 2(1) of Directive (EU) 2026/804 requires Member States to ensure that third-country branches taking eligible deposits on 11 May 2028 without DGS membership join a DGS by 11 August 2028.

An investment firm keeps its clients’ money with us on a segregated account. Is it eligible?

It can be. Circular CSSF-CPDI 16/02 states that the FGDL is competent for deposits even where the holder is an investment firm acting for its clients, and it applies the Article 174 look-through to omnibus accounts that investment firms use for client money, provided the clients are eligible and identified or identifiable before the guarantee is triggered. The shares are reported under legal persons, because the holder is a legal person, and also in 0226, 0255 and 0330. Without identifiable clients, the account fails the eligibility test in field 0201.

A Luxembourg municipality holds a deposit with us. Is it excluded as a public authority?

The answer depends on the counterparty’s BCL sector classification. Circular CSSF-CPDI 18/14 excludes counterparties classified as central government (code 11000) or other general government (code 12000) in the BCL’s definitions for credit institutions’ statistical reporting. If the municipality sits in either code, the deposit is excluded from 0201 but still counted in 0100. Directive (EU) 2026/804 narrows the exclusion to central and state governments once transposed.

Related Articles

• Deposit Guarantee Scheme Reporting in Luxembourg: FGDL Membership, SCV Files, and the Covered Deposits Survey: the wider FGDL framework, from membership and SCV files to risk-based contributions.
• CSSF-CODERES 26/22: SRF Data Reporting Due 15 January 2027: the Single Resolution Fund data reporting form in which covered deposits reduce the contribution base.
• Directive (EU) 2026/804 DGSD Amendment: What Changes for Deposit Protection Across Europe: scope, temporary high balances, client funds and cross-border changes in the amended DGSD.
• CMDI Reform Published in the Official Journal: What Changes for Crisis Management and Deposit Insurance: the three CMDI instruments and their application dates.
• BCL S 0.1 Report: Daily Deposit Reporting for Luxembourg Banks: the BCL statistical return on deposit liabilities, a separate dataset from the FGDL survey.

Key Takeaways

• Book the review by the authorised manager designated for FGDL membership ahead of Monday 16 November 2026, and confirm that the name on file with the CSSF and the FGDL is still current.
• File even with nothing to report: the circular makes a zero-filled transmission mandatory.
• Test the annex identities before approval, starting with 0320 = 0245 times EUR 100,000 and 0400 = 0201 minus 0300.
• Keep accounts in XAU, XAG or virtual currencies out of every field, total deposits included, while keeping interbank deposits in 0115.
• Archive S3 feedback files on receipt; the CSSF deletes them 20 days after creation.
• Route any correction after the deadline to cpdi@cssf.lu as soon as it is found, without waiting for the next quarter.
• Plan the year-end differently: the 31 December 2025 survey ran a 22-day window with a separate eDesk report for each EEA branch.

Sources and References

• CSSF, Circular CSSF-CPDI 26/52, Survey on the amount of covered deposits held on 30 September 2026 (2 October 2026): CSSF page and English PDF with annex
• CSSF, Circular CSSF-CPDI 26/51, survey at 30 June 2026 (1 July 2026): English PDF
• CSSF, Circular CSSF-CPDI 26/50, survey at 31 March 2026 (26 March 2026): English PDF
• CSSF, Circular CSSF-CPDI 25/49, survey at 31 December 2025 (24 December 2025): English PDF
• CSSF, Circular CSSF-CPDI 25/48, FGDL method for calculating ex-ante contributions (13 November 2025): CSSF page
• CSSF, Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35, scope of the deposit guarantee and investor compensation: English PDF
• CSSF, Circular CSSF 13/555 as amended by Circular CSSF-CPDI 23/36, Single Customer View file: CSSF page and English PDF
• CSSF, Circular CSSF-CPDI 18/14, definition of public authorities for the deposit guarantee exclusions (18 December 2018): PDF (French)
• CSSF, Circular CSSF-CODERES 26/22, SRF information request for the 2027 contribution: CSSF page
• Amended Law of 18 December 2015 on the failure of credit institutions and certain investment firms, CSSF English consolidated version: PDF
• CSSF, Deposit guarantee page (FGDL circulars and legal framework): CSSF page
• CSSF, Methods of transmitting reports via S3 Application Programming Interface: technical guidance (version 1.0, July 2023): PDF
• Directive 2014/49/EU on deposit guarantee schemes: EUR-Lex
• Directive (EU) 2026/804 amending Directive 2014/49/EU (OJ L, 20.4.2026): EUR-Lex
• Regulation (EU) No 806/2014 (SRMR), Articles 69 and 70: EUR-Lex
• Commission Delegated Regulation (EU) 2015/63 on ex-ante contributions to resolution financing arrangements, as cited in Circular CSSF-CPDI 25/49: EUR-Lex

Getting the 30 September 2026 covered deposits figures out the door

Circular CSSF-CPDI 26/52 leaves the survey content untouched, which puts the weight on execution: eligible balances filtered through Article 172 and Circular CSSF-CPDI 16/02, omnibus shares classified by the holder’s legal status, the annex identities holding, and the designated authorised manager’s approval recorded before the file goes to eDesk or the S3 submission folder.

The deliverable is that approved 30 September 2026 return, transmitted by Monday 16 November 2026. The next decision point is the year-end circular for 31 December 2026; its 2025 predecessor was dated 24 December and set a 22 January deadline.

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.