CSSF Remuneration Reporting: Who the Guide Really Covers

ByOfficer

Last updated: June 2026

Open the wrong remuneration file in a Luxembourg fund house and you can lose a week building a return nobody asked for. The CSSF updated its User Guide for remuneration reporting page on 3 June 2026, and the title alone sends fund teams down the wrong road. CSSF remuneration reporting, as that guide defines it, is a prudential data collection for banks and investment firms. It is not the channel through which a UCITS management company or an alternative investment fund manager discloses what it pays its people.

The phrase carries two meanings in Luxembourg: a supervisory collection that feeds an EU-wide benchmarking and high earners exercise, and a transparency obligation inside a fund’s own annual report. They share a vocabulary and little else.

Related reading: EBA High Earners Report 2024: What the Data Means for Remuneration Reporting

What the CSSF updated on 3 June 2026

The CSSF updated its User Guide for remuneration reporting page on 3 June 2026. The current PDF is version 1.5, dated 29 May 2026, and the CSSF document page marks it as relevant for credit institutions and investment firms. The guide explains how in-scope entities submit remuneration-reporting files to the CSSF.

Read the update for what it is. The CSSF page update on 3 June 2026 points to a version 1.5 PDF dated 29 May 2026; the change log shows operational updates to report-status wording, error code REM012, report follow-up dashboards and data-collection-year grouping, not a change to the EU legal basis. The guide covers procedures with different frequencies: remuneration benchmarking and high earners run annually, gender pay gap benchmarking runs every three years, approved higher-ratio reporting runs every two years, and diversity benchmarking is a separate EBA procedure. Take expected reports, deadlines and format from the current eDesk dashboard and CSSF guide, not a cached copy. It is not a public document, and it is not a fund report.

The legal basis: CRD Article 75 and IFD Article 34

Several EBA data-collection procedures sit under this guide. The core legal bases are the CRD and IFD remuneration oversight provisions, with separate EBA guidelines and CSSF circulars for remuneration benchmarking, high earners, approved higher ratios, gender pay gap benchmarking and diversity benchmarking. The remuneration benchmarking exercise rests on Article 75(1) of the Capital Requirements Directive (Directive 2013/36/EU) for credit institutions and Article 34(1) of the Investment Firms Directive (Directive (EU) 2019/2034) for investment firms. The high earners data collection rests on Article 75(3) of the CRD and Article 34(4) of the IFD. These articles instruct national competent authorities, the CSSF among them, to gather the data and pass it to the EBA.

The detail comes from EBA guidelines. Benchmarking follows the EBA Guidelines on the remuneration and gender pay gap benchmarking exercises, published on 30 June 2022 as EBA/GL/2022/06 under the CRD and EBA/GL/2022/07 under the IFD. The high earners collection follows the EBA Guidelines on the high earner data collection exercises under the CRD and IFD, EBA/GL/2022/08. Benchmarking now also covers the gender pay gap, first applying for the 2023 financial year.

Who actually files CSSF remuneration reporting, and who does not

Luxembourg’s market structure drives the confusion. The country is dominated by investment funds, so a reader sees “CSSF remuneration reporting” and assumes it lands on the fund management company. It does not. The collection captures credit institutions and those investment firms that fall under the remuneration provisions of the CRD or the IFD. A standalone UCITS management company or AIFM is supervised as an investment fund manager, not as a CRD or IFD investment firm, and it sits outside this collection.

The CSSF’s own reporting inventory confirms the point. The page listing the reporting to be submitted by investment fund managers covers financial information, supervisory documents, the AML summary report, SFDR data, real estate exposure data and AIFM reporting under Commission Delegated Regulation (EU) 231/2013. No remuneration benchmarking or high earners collection appears on it. A fund compliance team that opens the guide expecting an AIFM template should first check the entity scope line: the CSSF marks the guide for credit institutions and investment firms. What the rule does not mean is that fund managers have no remuneration obligations. It means those obligations live somewhere else.

The high earners collection and the EUR 1 million threshold

The high earners side has one number every in-scope firm watches: EUR 1 million. Competent authorities collect data on the number of natural persons per institution or investment firm remunerated EUR 1 million or more in a financial year, reported in pay brackets of EUR 1 million. For each high earner, the return captures the EUR 1 million payment bracket, job responsibilities, business area, gender and the main remuneration elements, including salary, bonus, long-term award and pension contribution.

Two errors recur. The first is currency and timing: the threshold is a strict EUR figure measured for the financial year, so firms paying in another currency must convert consistently and apply the test to the right financial year. The second is bracketing, since the return wants a distribution across EUR 1 million bands rather than a single count above the line. None of this is the same as your Pillar 3 disclosure. The public Pillar 3 remuneration templates come from Article 17 and Annex XXXIII of Commission Implementing Regulation (EU) 2021/637 under Article 450 CRR. Template EU REM4 discloses identified staff remunerated EUR 1 million or more, with EUR 500,000 bands from EUR 1 million to below EUR 5 million and EUR 1 million bands above EUR 5 million. Same threshold, different audience, different file.

Where UCITS managers and AIFMs report remuneration instead

If you manage funds, your remuneration transparency runs through the fund framework. For alternative investment fund managers, the remuneration policy obligation sits in Article 13 of the AIFMD (Directive 2011/61/EU) with the detailed principles in Annex II, covering staff whose activities have a material impact on the risk profiles of the AIFs. The annual report disclosure sits in Article 22 of the AIFMD, which requires the AIF annual report to set out the total remuneration paid by the AIFM to its staff, split into fixed and variable amounts, the number of beneficiaries, any carried interest, and the aggregate remuneration broken down by senior management and material risk takers.

The UCITS side mirrors it. The UCITS Directive (Directive 2009/65/EC), as amended by UCITS V (Directive 2014/91/EU), added Articles 14a and 14b requiring a remuneration policy for staff with a material impact on the managed UCITS, and Article 69 requires the equivalent disclosure in the UCITS annual report. The ESMA Guidelines on sound remuneration policies under the AIFMD and the UCITS Directive set the supervisory expectations the CSSF applies. That work flows into the annual report the auditor signs, governed by fund legislation, not through eDesk.

What to check before this cycle’s submission

For an in-scope bank or investment firm, a short pre-submission pass saves rework. Pull the current guide from eDesk, and confirm the financial year covered and the submission date stated in that version. Reconcile the benchmarking population against your Pillar 3 EU REM population. Check the EUR 1 million conversions and the bracket allocation. Populate gender pay gap, approved-higher-ratio or diversity fields only where the current eDesk dashboard shows an expected report or the relevant CSSF/EBA cycle applies. For a fund manager, confirm the disclosure is complete in the fund annual report under Article 22 of the AIFMD or Article 69 of the UCITS Directive, not an eDesk return that will never be requested.

Frequently Asked Questions

Does the CSSF remuneration reporting user guide apply to UCITS management companies and AIFMs?

No. The guide is marked for credit institutions and investment firms and supports the CRD and IFD benchmarking and high earners collections. The CSSF reporting inventory for investment fund managers does not list a remuneration collection. Fund managers report remuneration through the fund annual report instead.

What is the legal basis for the collection?

Benchmarking comes from Article 75(1) of the CRD (Directive 2013/36/EU) and Article 34(1) of the IFD (Directive (EU) 2019/2034). The high earners collection comes from Article 75(3) of the CRD and Article 34(4) of the IFD. The data feeds the EBA through the CSSF.

Who counts as a high earner?

A natural person remunerated EUR 1 million or more in a financial year. The data is reported in pay brackets of EUR 1 million, with the payment bracket, job responsibilities, business area, gender and the main pay elements of salary, bonus, long-term award and pension contribution.

Is this the same as the Pillar 3 remuneration disclosure?

No. The public Pillar 3 templates, including EU REM4 for identified staff paid EUR 1 million or more, come from Article 17 and Annex XXXIII of Commission Implementing Regulation (EU) 2021/637 under Article 450 CRR and are published to the market. The benchmarking and high earners collection is supervisory and goes to the CSSF and the EBA.

How does a fund manager disclose remuneration if not through this collection?

Through the fund annual report. Article 22 of the AIFMD and Article 69 of the UCITS Directive require the disclosure there, split into fixed and variable amounts with a breakdown for senior management and material risk takers, supported by the policy under AIFMD Article 13 and Annex II or UCITS Articles 14a and 14b.

Related Articles

Key Takeaways

  • The CSSF updated the User Guide page on 3 June 2026; the current PDF is version 1.5 dated 29 May 2026 and records operational changes to statuses, REM012 and follow-up dashboards.
  • The guide governs a prudential collection for credit institutions and investment firms, submitted through eDesk to the CSSF and the EBA.
  • High earners means natural persons paid EUR 1 million or more in a financial year, reported in EUR 1 million brackets with role and pay-element detail.
  • UCITS management companies and AIFMs are not in this collection; the CSSF reporting inventory for fund managers lists no remuneration return.
  • Fund managers disclose remuneration in the fund annual report under Article 22 of the AIFMD or Article 69 of the UCITS Directive, not the public Pillar 3 EU REM disclosure under Commission Implementing Regulation (EU) 2021/637.

Sources and References

Reading the guide for what it is

The updated user guide is a good document doing a narrow job: it moves benchmarking and high earners data from Luxembourg banks and investment firms to the CSSF and the EBA each year. The error is not in the guide. It is in the assumption that a file named “remuneration reporting” must be where every regulated firm reports remuneration. Match the guide to your entity type first, then decide whether you are filing a prudential return or completing an annual report disclosure. Only one of them lives in this guide.

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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