CSSF eRegister by eDesk: Prospectus Interface Joins the Fund Data API

ByRegReportingDesk
RegReportingDesk card: CSSF, Commission de Surveillance du Secteur Financier, Luxembourg

On 1 October 2026 the CSSF announced that eRegister by eDesk, the product it created to give financial sector professionals access to public information, now includes an interface for consulting prospectuses approved by the CSSF. The CSSF eRegister had gone live a month earlier with one feature: API access to the identification data of funds, sub-funds and share classes, available only to applicants who first sign an agreement with the CSSF.

Both announcements describe data travelling from the CSSF to the user, and neither adds a reporting or notification obligation. For Luxembourg fund and issuer teams that leaves two practical questions: whether to request API access at all, and whether the public data the CSSF holds about their own funds matches what they think they notified.

The name also invites a mix-up with the DORA register of information, which entities do file through eDesk. The two share a word and a portal.

Related reading: CSSF Prudential Reporting for PIs, EMIs and CASPs: The Move to eDesk

eRegister timeline and access conditions

The dates come from the two CSSF announcements:

  • 1 September 2026: the CSSF announces eRegister by eDesk, with API access to fund, sub-fund and share class identification data as the initial feature. The announcement was updated on 10 September 2026.
  • Early September 2026: the API functionality becomes available, as the October announcement recalls.
  • 1 October 2026: the interface for consulting CSSF-approved prospectuses is added, reachable through the link on the eDesk homepage and the toolbox on the CSSF website.
Feature Access condition stated by the CSSF Contact named
Identification data of funds, sub-funds and share classes (API) Prior signed agreement with the CSSF; natural or legal persons may apply; technical details and data specifications provided after signing Access requests: itcompliance@cssf.lu
Consultation interface for CSSF-approved prospectuses None stated in the 1 October announcement Queries: edesk@cssf.lu

Two mailboxes, two purposes. The September announcement sends access requests to itcompliance@cssf.lu, while the October one directs general queries and requests for additional information to edesk@cssf.lu.

The CSSF eRegister fund data API: what can be scoped before signing

Very little. The September announcement names three levels of data (funds, sub-funds and share classes) and one delivery method, an API. It then says that technical details and data specifications will be provided upon signing of the agreement. Neither announcement mentions a field list, refresh frequency, authentication method or fee, so a data team cannot size an integration from the public material alone.

The CSSF presents eRegister as a centralised, streamlined and universally accessible point of entry to public information, yet the first feature sits behind a bilateral agreement between the CSSF and the applicant, who may be a natural or a legal person.

There is an older source for the same kind of data. The CSSF already publishes a technical document, “Identifiers of UCI/SIF/SICAR”, which it describes as containing identifiers of funds, compartments and share classes for reporting and notification purposes. It is available only in French. The announcements do not say whether the API returns the same identifiers or whether the file will continue. A team that populates reporting from the file today has no published basis for assuming the API codes match, and the data specifications are where that gets confirmed.

Approved prospectuses in eRegister and the LuxSE publication route

Under Articles 6(2) and 34(2) of the Law of 16 July 2019 on prospectuses for securities, the CSSF has delegated publication of prospectuses approved under Regulation (EU) 2017/1129 (the Prospectus Regulation) or under that Law, together with related documents, to the Luxembourg Stock Exchange. Those documents are published on luxse.com, as the CSSF’s prospectus page states. The October announcement does not mention that delegation or any change to it.

The CSSF’s page also states that the issuer, the offeror or the person applying for admission to trading on a regulated market remains bound by its own publication requirements under the Prospectus Regulation and Chapter 1 of Part III of the Prospectus Law. I read the eRegister interface as an additional consultation route for professionals; an issuer’s publication arrangements stay where the Prospectus Regulation and the Prospectus Law put them. For the EU disclosure rules running on a separate track, see our note on the ESMA prospectus disclosure guidelines consultation.

The scope matters for fund teams. The CSSF tags the October announcement under the topic “Prospectus” with the keyword “Securities prospectus”, and the text does not mention UCI offering documents. The CSSF’s page on amending an existing UCI shows one such path: for the new sub-fund procedure, it states that the final clean version of the prospectus or offering document has to be submitted through the eDesk e-Identification Prospectus application. Whether UCI prospectuses appear in eRegister is not addressed in either announcement.

eRegister and the DORA register of information are different instruments

The DORA register of information is a filing. Article 28(3) of Regulation (EU) 2022/2554 requires financial entities to maintain and update a register of information on all contractual arrangements for ICT services provided by ICT third-party service providers. Financial entities required to submit their register of information to the CSSF do so annually through the eDesk module “Submission of the Register of Information”; for the 2026 collection, the CSSF expressly excluded entities under the direct supervision of the ECB. For the 2026 cycle the CSSF set the submission window from 11 February to 31 March 2026, with a reference date of 31 December 2025, and required plain CSV files enclosed in a ZIP file that follows a predefined folder structure. Our DORA register of information guide covers the templates.

eRegister runs in the opposite direction. It gives professionals access to public data the CSSF already holds and asks nothing of the entities that data describes. Neither eRegister announcement refers to DORA, and neither changes the register of information cycle.

Funds do use eDesk for genuine notifications too. Since 21 September 2026, for example, Luxembourg UCIs under the Law of 17 December 2010, SIFs and SICARs notify the activation and deactivation of a redemptions-only suspension (a suspension of redemptions without suspension of subscriptions) through the eDesk “LMT activation” module, while supporting documentation continues to go through the usual CSSF communication channels, as covered in our note on the CSSF LMT activation module for redemptions-only suspensions.

Changes to existing UCIs follow separate CSSF procedures

The eRegister announcements describe access to public information and, for the API, identification data of funds, sub-funds and share classes. Neither announcement describes a mechanism for correcting an eRegister record. Separately, the CSSF publishes procedures governing changes to existing UCIs, including additional sub-funds, qualifying new share classes and other amendments. Its page on amending an existing UCI (last updated 12 March 2026) separates them by type of change:

  • A new sub-fund, subject to the CSSF’s separate ELTIF procedure where applicable: the standard process uses the “Questionnaire for the approval of a new sub-fund”, with appended documents submitted by email to setup.uci@cssf.lu, followed by the final clean prospectus or offering document through the eDesk e-Identification Prospectus application. In certain cases the questionnaire must be accompanied by the AML/CFT Market Entry Form. For an ELTIF sub-fund, the CSSF directs applicants to its dedicated ELTIF procedure; for ELTIF authorisation of a sub-fund within a Part II UCI, SIF or SICAR, the standard new-sub-fund questionnaire is not required.
  • A new share class whose characteristics are already defined in the current prospectus: the simplified procedure, using the standardised table in the form and sent exclusively to opc_signa@cssf.lu.
  • Other amendments, such as a change of registered address, a change of management regulations or articles of incorporation, or a corporate action such as a spin-off: a request file sent to amendments.uci@cssf.lu.

The simplified share class route has a hard edge. It applies only where all characteristics of the new class are already covered and defined in the current version of the prospectus and no new specificities are introduced. A class that introduces a new specificity does not qualify for it.

Frequently Asked Questions

Can an individual apply for eRegister API access, or only firms?

Both. The September announcement says access requires the prior signing of an agreement between the CSSF and the applicant, whether natural or legal person. It publishes no further eligibility criteria and no agreement text.

Does consulting approved prospectuses in eRegister require the API agreement?

The agreement condition in the September announcement attaches to the API functionality. The October announcement gives the access route for the prospectus interface, through the eDesk homepage link and the CSSF website toolbox, and states no agreement condition. The 1 October announcement describes the prospectus feature as an interface for consulting CSSF-approved prospectuses, and neither eRegister announcement mentions an API for prospectuses.

A share class shows outdated identification data in eRegister. Where is that corrected?

Neither announcement describes a correction function. The CSSF publishes separate procedures for changes to existing UCIs, listed above. Questions about the eRegister record itself go to edesk@cssf.lu.

Key Takeaways

  • Issuers: the CSSF’s publication of approved prospectuses stays delegated to the Luxembourg Stock Exchange under Articles 6(2) and 34(2) of the Prospectus Law, and the issuer remains bound by its own publication requirements; eRegister adds a consultation view.
  • Fund teams: for the new sub-fund procedure and for the other amendments described above, the CSSF requires the final clean prospectus or offering document including the change to be submitted through the eDesk e-Identification Prospectus application; neither eRegister announcement says whether UCI prospectuses or offering documents appear in eRegister.
  • DORA: the register of information keeps its own annual eDesk submission; the 2026 window ran from 11 February to 31 March 2026 for a 31 December 2025 reference date.
  • New share classes: the simplified procedure via opc_signa@cssf.lu is limited to classes already defined in the current prospectus, with no new specificities.
  • Reporting teams that draw codes from the “Identifiers of UCI/SIF/SICAR” file: keep it as the reference until the API data specifications show the codes match.

Sources and References

The first artifact: an eRegister access request to itcompliance@cssf.lu

For a team that wants fund, sub-fund and share class identification data by machine, the next step is the access request to itcompliance@cssf.lu. The CSSF states that the technical details and data specifications will be provided upon signing of the agreement; the public announcement itself does not provide an API field list.

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.

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