BCL S 3.2 Reporting: Loan-to-Value and Deposit Account Counts

Twice a year, every credit institution resident in Luxembourg sends the Banque centrale du Luxembourg (BCL) report S 3.2 “Non-balance sheet information”: one loan-to-value ratio for house-purchase loans granted to households during the half-year, and four counts of deposit accounts held by customers other than monetary financial institutions (MFIs). BCL S 3.2 reporting falls due no later than 20 calendar days after the end of June and the end of December, and the layout in force, layout 0, has been mandatory since the December 2014 reference period.

The report has five lines. Its instructions, template and verification rules all carry the same 17 July 2014 update date on the BCL’s S 3.2 page, and that stability cuts both ways. The definitions do not mention smartphone banking apps, and the instructions say nothing about several loan and account cases that a mortgage book or a deposit system can produce in any half-year.

Related reading: BCL S 0.1 Report: Daily Deposit Reporting for Luxembourg Banks

Legal basis of BCL S 3.2 reporting: Article 32 of the BCL law and Circular 2014/235

The S 3.2 instructions (July 2014) and the compendium of verification rules describe the reporting population, the frequency and the five items. Neither document names an ECB regulation, a BCL regulation or an article of law as the legal basis of the report. That silence matters later, when the question is which compliance framework applies to the file.

The statutory power behind the BCL’s statistical collections is Article 32(1) of the amended Law of 23 December 1998 on the monetary status and the Banque centrale du Luxembourg. It empowers the BCL, in order to undertake its tasks, to collect the statistical information it needs either from the competent national authorities or directly from economic agents. Article 32(2) places the individual information collected under professional secrecy, and Article 32(3) allows the BCL to publish the statistics it compiles only where publication neither contains nor permits the inference of individual information. The S 3.2 documents do not cite Article 32; tying it to S 3.2 is an interpretation of how the BCL’s collections are built.

The instrument that created the report in its current form is Circular BCL 2014/235 of 20 January 2014, “Modification of the statistical data collection of credit institutions”. The circular followed the adoption on 24 September 2013 of Regulations ECB/2013/33 on the balance sheet of the MFI sector (recast) and ECB/2013/34 on MFI interest rate statistics (recast). Section 2.3 of the circular explains what happened to this report: the former report S 4.1 “Non-balance sheet information” had its reporting frequency increased, was renamed S 3.2, and gained information on the loan-to-value ratio and the number of accounts. Section 3 lists S 3.2 among the reports whose structure had to be modified, and Section 7 makes the new collection mandatory from the December 2014 deadline, with the first reports relating to the end of December 2014.

The circular sets objectives for the whole collection, among them coverage of the ECB’s foreseeable requirements in monetary and financial statistics, coverage of the needs of BCL units and of STATEC, the national statistics institute, and a lighter workload for reporting agents. It does not say which of those needs the loan-to-value line or the account counts serve.

Two later facts complete the picture. The BCL’s list of circulars now places 2014/235 among repealed or obsolete circulars, so the S 3.2 instructions on the BCL’s report page are the operative description of the report. And Regulation ECB/2013/33 has since been recast as Regulation (EU) 2021/379 (ECB/2021/2). Circular BCL 2021/244 of 10 February 2021, which implemented that recast in the BCL’s collection, lists the reports affected by its update of definitions, and S 3.2 is not on that list. The four overnight-deposit account measures also appear in Annex III, Table 1, of ECB Regulation (EU) No 1409/2013 (ECB/2013/43) on payments statistics, as amended by Regulation (EU) 2020/2011 (ECB/2020/59). That table is headed as end-of-period data, with numbers in actual units, and the framework collects it on a semi-annual basis.

For ECB payments statistics, the definition of non-MFIs excludes all payment service providers (PSPs), including PSPs that are not classified as MFIs. Section 2.2 of the BCL S 3.2 instructions excludes MFIs but does not state an equivalent PSP exclusion. The two reporting populations must therefore not be assumed identical. Whether and how S 3.2 maps to the ECB payments-statistics measures should be confirmed with the BCL. The BCL documentation reviewed does not expressly establish how S 3.2 maps to that ECB collection, or which ECB requirement, if any, governs its LTV line.

Who must report S 3.2: resident credit institutions, accounting version L only

Section 1.1 of the instructions is one sentence: report S 3.2 must be provided by all resident credit institutions regardless of their legal status. The documents set no size threshold, no activity threshold and no exemption. A bank with no retail deposits and no mortgage lending is still in scope, and the verification rules described below make it send zero-valued lines.

The BCL’s S 3.2 instructions establish semi-annual reporting, and its 2026 calendar and electronic-transmission manual identify the return as S 3.2 L0. The BCL’s current S 3.2 reporting page does not list a separate S 3.2-N return. The applicable accounting population should be read alongside the general version L and version N definitions in the DCBAN document. The BCL’s definitions document for credit institutions (DCBAN, July 2024) explains the versions. Version L covers the Luxembourg head office, without eliminating operations with its own branches. Version N covers the head office together with its foreign branches, with intra-group transactions eliminated. Luxembourg-law banks without foreign branches, and Luxembourg branches of credit institutions governed by foreign law, file a single version L.

Three filing answers follow:

• A Luxembourg-law bank with branches abroad files one S 3.2 for the Luxembourg entity. There is no S 3.2-N, unlike S 2.5-N for the quarterly balance sheet.
• A Luxembourg branch of a foreign-law credit institution, whether its head office sits in another EU Member State or outside the EU, files S 3.2 in version L. The instructions’ “regardless of their legal status” wording and the DCBAN treatment of such branches point the same way; neither document carves branches out.
• No group-level or consolidated S 3.2 exists. Each resident credit institution is its own declarant.

One naming trap sits here. The “L0” in the calendar heading “S 3.2 L0” and in the file name “S0302_L0” is the layout number, and the BCL’s electronic transmission manual says so explicitly: L0 indicates layout 0. The accounting version is a separate attribute from the layout. A team that reads “L0” as “version L, Luxembourg only” reaches the right scope by the wrong route.

What the S 3.2 report contains: one ratio and four account counts

The BCL’s published verification compendium identifies five S 3.2 data lines: one loan-to-value measure and four overnight-deposit account measures. Their published line identifiers do not include country, currency, sector or maturity breakdown suffixes. The exact workbook structure and column labels should be taken from the current BCL Excel template.

Line 1-002020-LTVR: the loan-to-value ratio

Section 2.1 of the instructions defines the loan-to-value ratio (LTVR) of a mortgage loan as the relation between the value of the loan and the price of the property acquired. The item covers the value of all newly granted mortgage loans to households, resident in Luxembourg or not, during the reference period, in relation to the acquisition value of property located in Luxembourg. Only loans granted for the purpose of house purchase count. Loans for building renovations are excluded, and so are renegotiations of loans. The French version, which prevails in case of discrepancy, uses wider wording: it counts loans intended for the acquisition of a real estate property (bien immobilier) located in Luxembourg, so whether a household loan to buy a building plot or a non-residential property enters the average is a point to confirm with the BCL.

The ratio is a simple arithmetic average: the sum of all individual LTVRs divided by the number of loans. A EUR 150,000 loan carries the same weight as a EUR 2 million loan. A system that produces an amount-weighted LTV for risk reporting can give a different number, and the S 3.2 definition does not allow it. The instructions add that the ratio is in principle below 100% but may exceed it in some cases.

The line code reuses the balance-sheet item code 1-002020, which in the BCL’s statistical balance sheet is the lending-for-house-purchase line under loans. The population is much narrower here: new business in the half-year, households only, Luxembourg property only, purchase purpose only. The S 1.1 period-end loan stock can miss loans granted and fully repaid during the half-year, and the S 1.1 house-purchase category also includes building and refurbishment loans that S 3.2 excludes. Build the S 3.2 population from origination records covering the entire reference period, selecting qualifying household house-purchase loans for property in Luxembourg and excluding renovation loans and renegotiations.

The format of the number is an open point. The instructions describe the ratio in percentage terms. No S 3.2 document reviewed states whether 75% travels as 0.75 or as 75, and that is a question to settle with the BCL in writing before the first file.

Lines 2-002010 and 2-002011: counting deposit accounts

Section 2.2 limits all four counts to accounts held with the reporting institution by customers other than MFIs. In the BCL’s sector nomenclature the MFI sector is code 30000, so accounts of the central bank, credit institutions and other MFIs stay out, while accounts of the public sector, households, non-financial corporations and non-MFI financial customers come in.

The overnight deposit definition behind 2-002010 is broader than “current accounts”. It covers deposits convertible into currency and/or transferable on demand by cheque, banker’s order, debit entry or similar means without significant delay, restriction or penalty, and it expressly includes:

• non-transferable balances convertible into currency on demand or by close of business on the following day without significant penalty;
• balances representing prepaid amounts in hardware-based or software-based e-money, such as prepaid cards;
• loans to be repaid by close of business on the day after they were granted;
• margin payments under derivative contracts that are cash collateral against credit risk, remain the depositor’s property and are repayable when the contract is closed out.

Cash margin arrangements and prepaid e-money balances require examination because the BCL includes the relevant instrument categories within its overnight-deposit definition. However, S 3.2 counts qualifying accounts, not individual balances, prepaid cards or margin transactions. A balance must not automatically be treated as one additional account. The reporting institution should establish whether the arrangement constitutes a distinct overnight deposit account held by a non-MFI customer and seek BCL clarification for pooled or ledger-only arrangements.

The transferable subset behind 2-002011 is narrower: overnight deposits directly transferable on demand to make payments to other economic agents by credit transfer, direct debit, card, e-money, cheque or similar means. Current accounts are included. Deposits that can only be used for cash withdrawal, and deposits from which funds can only be withdrawn or transferred through another account of the same owner, are excluded. These definitions match, almost word for word, those the BCL’s DCBAN document gives for the S 1.1 liability items 2-002010 (overnight deposits) and 2-002011 (the transferable deposits within them), and the line codes are the same. The corresponding S 1.1 items provide a classification and plausibility cross-check, but they do not themselves define the complete account-level population for S 3.2. Construct the counts from the inventory of qualifying non-MFI overnight-deposit accounts and reconcile the results against the relevant S 1.1 categories. The published cross-report rule requires a positive S 3.2 account count where specified S 1.1 non-MFI overnight-deposit balances are positive; it does not establish account-by-account equivalence or resolve the treatment of dormant and zero-balance accounts.

The “o/w Internet/PC-linked” lines count accounts the holder can access and use electronically via the internet or PC banking, using dedicated software and telecommunication lines, to make payments. Accounts accessible by landline or mobile phone are excluded unless they are also accessible via the internet or PC banking.

One convention comes from the verification rules: every line must show a credit trend or zero, which rules out negative values. The S 3.2 instructions do not expressly specify the observation date for the account counts. The corresponding four account measures in Annex III, Table 1, of the amended ECB payments-statistics regulation are explicitly end-of-period measures reported in actual units. This supports taking account snapshots at 30 June and 31 December, consistently with the BCL’s general reference-date convention (the DCBAN rule that the last day of the month is in principle the reference date). The BCL should confirm the direct application of that convention to S 3.2, including treatment of accounts without an outstanding balance. No rounding rule specific to S 3.2 is published; the DCBAN minimum standards require reporters to follow the dimensions, decimals and rounding policy the BCL sets for transmission.

S 3.2 deadlines: June and December reference dates, 20 calendar days to file

Section 1.2 of the instructions sets the rhythm: S 3.2 is provided to the BCL on a semi-annual basis no later than 20 calendar days after the end of the reference period, and the BCL publishes a calendar with the remittance dates. The fixed pattern is a reference period ending 30 June, filed by 20 July, and a reference period ending 31 December, filed by 20 January of the following year. The first reference date under the current layout was the end of December 2014, per Circular 2014/235 and the BCL’s S 3.2 page.

The calendar, dated December 2025, carries a footnote that its deadlines are based on the working days defined by the ECB for the transmission of statistics by national central banks. Each year’s calendar is therefore the document that fixes the exact date, and the 20-calendar-day rule in the instructions is the default it starts from. The inventory adds two operational points: the deadlines for semi-annual reports are those in the published calendar, and the BCL must be informed of any delay by mail and/or electronic mail.

Sequencing with S 1.1 deserves a line in the close plan. In the 2026 calendar the June S 1.1 L6 monthly balance sheet is due on 14.07.2026, six days before the June S 3.2. By the time the semi-annual file goes in, the month-end balance sheet it is cross-checked against is already with the BCL.

The S 3.2 documents set no separate deadline for corrections. Where the BCL asks for a correction or confirmation, the deadline is the one the BCL specifies in its feedback, as described in the validation section.

Submission of the S0302 XML file through Sofie or e-file

S 3.2 is transmitted in XML using the schema package linked from the BCL’s current S 3.2 reporting page. The internal package version, constituent XSD files, element structure and numeric restrictions must be verified directly from that official ZIP before they are used as an implementation specification.

The BCL’s “Manual of electronic transmission for statistical reports of credit institutions” (February 2021) fixes the file name as S0302_L0_yyyymm_Rrrrrrrrrr_Dddddddddd_yyyymmdd_nnn. The yyyymm block is the reference month, R and D identify the type of reporter and declarant, the nine-digit identifiers are the numbers allocated by the CSSF and padded with leading zeros, the second date is the file’s creation date, and nnn is a sequence number that restarts at 001 each day; 000 must not be used.

Any sample XML distributed with the BCL schema package should be treated as technical test material rather than as evidence of reportable values or valid combinations of data items. Before using it in testing, compare its identifiers and numerical examples with the current report template, published verification rules and official schema. The sample must not override the report’s mandatory-line and account-subset requirements.

On channels, Section 2.4 of the manual states that the BCL accepts the electronic transmission channels offered by Sofie (SIX Payment Services (Europe) S.A., CETREL Securities) and e-file (Bourse de Luxembourg, Fundsquare), and remains willing to accept any new secure channel agreed by the BCL and reporting agents. BCL circular letter ST.24-0013 of 15 January 2024 closed the e-mail route: the BCL no longer accepts statistical reports by e-mail and asked reporters to set up transmission through e-file or Sofie.

The S 3.2 documents describe no resubmission procedure of their own. The daily sequence number is what distinguishes several files sent on the same day, and the DCBAN minimum standards require reporting agents to follow the BCL’s revision policy and to accompany revisions that deviate from regular revisions with explanatory notes.

Validation rules: what the S 3.2 compendium checks and what makes a file fail

The “Compendium of verification rules for report S 3.2” (July 2014) contains only permanent rules, which the BCL invites software providers to implement. They fall into four groups.

The four ordering relationships are 2-002010-TRAD => 2-002010-INTE, 2-002011-TRAD => 2-002011-INTE, 2-002010-TRAD => 2-002011-TRAD and 2-002010-INTE => 2-002011-INTE. The compendium does not spell the symbol out. Read together with the “of which” structure of the template and the instruction that transferable deposits sit within overnight deposits, the likely reading is “greater than or equal to”: an of-which count cannot exceed its parent, and the transferable counts cannot exceed the overnight counts. That reading should be confirmed with the BCL; a file that breaks it would also contradict the definitions themselves.

The cross-report rule ties S 3.2 to the monthly balance sheet. If S 1.1 reports a positive amount on line 2-002010 for the public sector (10000), the non-financial sector (20000) or the financial sector other than MFIs (40000), in any country and currency, at least one of the four S 3.2 account lines must be positive. MFI deposits (30000) do not trigger the rule, which matches the non-MFI scope of the counts. The compendium dates from July 2014 and names those aggregate sector codes; the current S 1.1 layout 6 template, introduced with the February 2021 instructions, reports deposit lines by sub-sector codes such as 11000 central government and 22000 households and non-profit institutions serving households. The compendium has not been restated in those codes.

A file can pass the schema and still fail the compendium. The BCL verification compendium requires the LTV line and the two TRAD account lines even when their values are zero. Whether the XML schema independently enforces their presence is a separate technical question that must be checked against the official XSD. A filing implementation must enforce the published mandatory-line rule regardless of whether that constraint is expressed in the schema. The transmission manual warns about a related gap: the schema contains format constraints but does not necessarily specify the validity of a code that respects the format. Taken together, the rules make these the predictable failure points:

• a missing 1-002020-LTVR line because no house-purchase loans were granted, where the rule requires the line with a zero value;
• an “o/w Internet/PC-linked” count above its parent, or more transferable accounts than overnight accounts, after a product reclassification in only one of the two extracts;
• zero account counts while S 1.1 shows non-MFI overnight deposits;
• a negative value or a sequence number of 000.

The BCL published a standard feedback model covering S0302 in April 2025. Its implementation was announced as a staged rollout, with reporting agents to be notified before feedback for each report type moved to the designated channels. The April 2025 note does not establish the date on which that process became operational for S0302. The note, titled “Feedbacks for the statistical reports”, announces up to three feedback types: FL-OK or FL-NOK on the technical status of the file, DQ-FDB on data points the BCL needs corrected or confirmed, and ADHC-FDB for ad hoc requests outside the normal production cycle. It places the move of feedback delivery from e-mail to the Sofie and e-file channels under Circular BCL 2021/243 and aligns it with the process the BCL already runs for AnaCredit (see our note on AnaCredit v1.0.15 and the BCL’s SDMX schemas). Feedback files are named FDBBUSI_[date of feedback]_[name of entry file]_[feedback type]_[BCL exchange ID].[extension]. Each feedback carries its own BCL deadline, and the note states that compliance with it falls within the ECB’s non-compliance framework under Regulation (EU) 2022/1917 (ECB/2022/31) and circular letter ST.24-0013.

Caveats: definitional gaps and overlaps with CSSF and payment statistics returns

The S 3.2 documents contain no proportionality measure, no waiver, no national discretion and no transitional provision. The burden is already small, five lines twice a year, and the only relief in the rules is that a zero is an acceptable value on the mandatory lines.

The gaps are definitional, and four of them recur:

• App banking. The Internet/PC-linked definition dates from 2014: internet or PC banking with dedicated software and telecommunication lines, with phone access excluded unless the account is also reachable via internet or PC banking. It does not mention smartphone applications. How an account usable for payments only through a mobile app should be classified is a question the text does not answer, and the answer moves both “o/w” lines.
• LTV format and population edges. As set out above, the transmission format of the ratio is unstated, and the instructions do not deal with mixed-purpose loans or with mortgages switched from another lender (see the FAQ).
• Record keeping. DCBAN requires monthly and quarterly statistical reports and related documents to be kept for twenty-four months. It does not mention semi-annual reports such as S 3.2.
• Copies to the CSSF. Circular BCL 2014/235 contained a historical reminder about sending copies of BCL reports to the CSSF. The CSSF’s current credit-institution reporting guidance states that the BCL/CSSF double-submission process has been abolished: credit institutions no longer need to send the CSSF duplicate statistical reports already submitted to the BCL. The old circular’s instruction should not be treated as a current parallel-filing requirement.

The loan-to-value line invites comparison with the CSSF’s macroprudential data, and the two do not measure the same thing. Circular CSSF 18/703, as amended by Circulars CSSF 20/737, 21/772 and 26/908, runs a separate semi-annual collection of residential real estate indicators, with reference dates of 31 December and 30 June and collection in April and October. Its scope is loans taken to purchase residential real estate in Luxembourg and secured by real estate collateral located in Luxembourg; loans granted to legal entities are excluded, and renovation loans secured by real estate are included. S 3.2 excludes renovation loans, measures the loan against the acquisition value, and averages without weighting. The two LTV figures cover different populations under different definitions, so they need not agree. The CSSF side is covered in our ESPREP-RES guide to the CSSF real estate lending returns.

The account counts have a neighbour too. The same BCL inventory lists the monthly payment statistics reports, among them V 1.220 “Stock of accounts (except e-money accounts)” and V 1.230 “Number of customers”. The S 3.2 instructions do not refer to them, and the S 3.2 compendium contains no rule linking the two. The DCBAN minimum standards do require a reporting agent to be able to explain the developments its data imply and to quantify any deviation from the BCL’s definitions, so a bank filing both should keep the bridge between the two account populations on file.

The last open point is the compliance framework. The scope of the ECB non-compliance framework cannot be determined solely by looking for the S 3.2 report code in Annex I to circular letter ST.24-0013. That annex identifies ECB legal instruments and reporting populations rather than individual BCL file codes. It lists both Regulation (EU) 2021/379 on MFI balance-sheet statistics and Regulation (EU) 2020/2011 amending the ECB payments-statistics framework, with credit institutions among the reporting agents of the latter. The BCL’s April 2025 feedback note separately names S0302 and places feedback deadlines within the framework of Regulation (EU) 2022/1917. The application of the ECB infringement framework to the individual S 3.2 data items, particularly the LTV measure, should be confirmed with the BCL; the absence of the S0302 code from Annex I does not establish an exemption. The English versions of the S 3.2 documents defer to the French text in case of discrepancy.

Changes to S 3.2: a 2014 layout, newer plumbing, and the IReF horizon

The report itself has not changed since 2014. The BCL’s S 3.2 page shows layout 0 as mandatory from the December 2014 reference period, with the instructions, template and verification rules each dated 17.07.2014 and published alongside versions with revision marks. The February 2022 inventory and the 2026 calendar both still show S 3.2 at layout L0.

The changes have come around the report:

• February 2021: Circular BCL 2021/244 implemented the ECB/2021/2 recast in the BCL’s collection, with the modified reporting mandatory from the January 2022 deadline. S 3.2 is absent from its list of affected reports.
• January 2024: circular letter ST.24-0013 announced that the ECB and the BCL would monitor compliance with the statistical reporting requirements of ECB regulations and decisions from the April 2024 reference period, and ended statistical reporting by e-mail.
• July 2024: the BCL updated its DCBAN definitions document, whose overnight and transferable deposit definitions match those in the S 3.2 instructions.
• April 2025: the BCL announced the staged move of feedback for S0302 and other statistical reports to Sofie and e-file.

The larger change is European. On 8 June 2026 the ECB announced the main milestones for the Integrated Reporting Framework (IReF): a public consultation on the draft IReF Regulation planned for the second half of 2027, a one-year pilot phase starting in the second quarter of 2030, and the first official IReF reporting in the second quarter of 2031, with an initial one-year parallel phase during which existing statistical reporting within the IReF scope continues. The ECB states that these timelines are subject to adoption of the IReF Regulation, pending the outcome of the consultation. Neither the press release nor the BCL’s IReF page names individual national reports. Both say that an implementation plan, still in preparation, will set out how national collection frameworks evolve and how residual country-specific requirements are modelled. Whether S 3.2’s two blocks move into IReF, survive as a residual Luxembourg requirement or disappear is not yet public. The governance side of that integration work runs through the Joint Bank Reporting Committee, covered in our JBRC reporting contact group article.

Frequently Asked Questions

A household moves its existing mortgage to us from another bank. Does that loan enter line 1-002020-LTVR?

The instructions count newly granted mortgage loans for the purpose of house purchase and exclude renegotiations, but they do not mention a loan switched from another lender. The contract is new at your bank, while its purpose is to refinance a purchase already made. A pure refinancing may fall outside a house-purchase average, but the text does not settle it, so record the BCL’s answer before the first such loan is reported.

One loan contract finances both the purchase of a house and renovation works. How is it treated?

The instructions say only that loans for the purpose of house purchase count and that renovation loans are excluded; a mixed-purpose contract is not addressed. The CSSF real estate collection, which includes secured renovation loans in its own scope, is no guide here. A rule agreed with the BCL, such as classifying by main purpose and applying it the same way every half-year, keeps the series consistent.

Do accounts held by money market funds or by other investment funds count?

Money market funds are part of the MFI sector (sector code 33000 within 30000 in the BCL nomenclature), so their accounts stay out of all four counts. Non-money-market investment funds carry sector code 41000 in the non-MFI financial sector, so their overnight deposit accounts count, and their transferable accounts count on 2-002011 as well.

A client holds three current accounts and a savings account that can only be emptied into one of those current accounts. What does that add to the counts?

The report counts accounts, not customers, so the three current accounts add three to 2-002010-TRAD and three to 2-002011-TRAD, current accounts being listed as transferable. The savings account adds one to 2-002010-TRAD only if its balance qualifies as an overnight deposit; because funds can only leave through another account of the same owner, it stays out of 2-002011. If it is a deposit redeemable at notice, it is not an overnight deposit and is not counted at all. The instructions do not address joint accounts.

Can our outsourcing provider submit S 3.2 on our behalf?

The transmission manual separates the reporter, the entity that submits the file, from the declarant, the entity whose data are reported. Banks are identified with type 23 and the letter B, and professionals of the financial sector with type 32 and the letter P, both using CSSF-allocated numbers. A provider that is a professional of the financial sector can therefore appear as reporter, while the declarant block and the D segment of the file name still identify the bank.

We missed the S 3.2 remittance date by two days. What do the rules say?

The BCL’s inventory requires the BCL to be informed of any delay by mail and/or e-mail. The S 3.2 documents set no late-filing consequence of their own. Under Article 8(2)(d) of Regulation (EU) 2022/1917, any two consecutive alleged infringements of semi-annual reporting requirements count as a cumulative alleged infringement. That threshold does not create a general exemption for an isolated late filing: Article 8(3) also permits infringement proceedings in cases not covered by Article 8(1), taking the circumstances of the case into account, and serious misconduct is addressed separately. Article 8 also sets two limits: Article 8(7)(a) bars proceedings over a late report whose potential fine is not likely to exceed EUR 10,000, and Article 8(6) bars them, except in cases of serious misconduct, where the delay arose from circumstances beyond the reporting agent’s control, which expressly excludes technical and IT infrastructure difficulties. Circular letter ST.24-0013 lists the amended ECB payments-statistics framework among the covered collections, while the precise application of that framework to S 3.2 remains a matter for BCL confirmation.

Related Articles

• BCL S 0.1 Report: Daily Deposit Reporting for Luxembourg Banks: the BCL’s high-frequency deposit return, transmitted under the same manual and channels as S 3.2.
• ESPREP-RES Reporting in Luxembourg: CSSF Real Estate Lending Data: who files the CSSF residential and commercial real estate lending returns, what the templates hold and when they fall due.
• AnaCredit v1.0.15: BCL Swaps the NUTS 3 Code List for January 2027: the BCL’s AnaCredit schema update and the feedback model its statistical reports are moving towards.
• JBRC Reporting Contact Group: What the Call for Members Means: the Joint Bank Reporting Committee behind the integration of statistical, prudential and resolution reporting.
• BCL Financial Stability Review 2026: The Luxembourg Risk Map: the BCL’s 2026 review of household debt, real estate, bank capital and fund liquidity risks.

Key Takeaways

• Diary two S 3.2 dates a year: 20 July for the June reference period and 20 January for December, then check each year’s BCL calendar for the exact date.
• File one S 3.2 per resident credit institution, in accounting version L; a Luxembourg bank’s foreign branches stay outside it, and a Luxembourg branch of a foreign bank files its own.
• Send 1-002020-LTVR, 2-002010-TRAD and 2-002011-TRAD in every file, at zero where there is nothing to report.
• Build the LTV as an unweighted average over the half-year’s new Luxembourg house-purchase loans to households; renovation loans and renegotiations stay out.
• Reconcile S 3.2 account counts to the June and December S 1.1 overnight deposit lines before submission, because non-MFI deposits with zero counts fail the cross-check.
• Route the XML through Sofie or e-file under the S0302_L0 file name; e-mail is no longer accepted.
• Obtain written BCL answers on the LTV transmission format, the property scope under the prevailing French wording, app-only accounts, mixed-purpose loans and switched mortgages.
• Track the IReF implementation plan; the ECB plans its pilot from Q2 2030, and S 3.2’s place in IReF is unpublished.

Sources and References

• BCL, S 3.2 “Non-balance sheet information” reporting page (layout 0 mandatory from the December 2014 reference period): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/S0302/index.html
• BCL, Report S 3.2 “Informations non bilantaires”, instructions, prevailing French version (July 2014): https://www.bcl.lu/fr/reporting_reglementaire/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/S0302/S0302_L0_instructions_FR.pdf
• BCL, Report S 3.2 template: https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/S0302/S0302_L0_report_EN.xls
• BCL, Compendium of verification rules for report S 3.2 (July 2014): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/S0302/S0302_L0_VER_EN.pdf
• BCL, S 3.2 XML schema package (as linked from the S 3.2 page): https://www.bcl.lu/fr/reporting_reglementaire/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/S0302/S0302_L0_XML.zip
• BCL, Definitions and concepts for the statistical reporting of credit institutions (DCBAN L2, July 2024): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/CI_Definitions_Concepts_2024_EN.pdf
• BCL, Manual of electronic transmission for statistical reports of credit institutions (February 2021): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/Electronic_transmission_CIS_EN.pdf
• BCL, Inventory of statistical reporting requirements for credit institutions (February 2022): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Bank_Inventory_statistical_reporting_2022_EN.xls
• BCL, Calendar of remittance dates for the statistical reporting of credit institutions in 2026 (December 2025): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Calendrier/Bank_Reporting_dates_2026.pdf
• BCL, Feedbacks for the statistical reports (April 2025): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/EN-Feedbacks—INS—2025_04.pdf
• BCL, Report S 1.1 L6 instructions (February 2021): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/S0101/S0101_L6_instructions_2021_EN.pdf
• BCL, Report S 1.1 L6 template: https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Instructions/S0101/S0101_L6_report_2021_EN.xls
• Circular BCL 2014/235 of 20 January 2014, Modification of the statistical data collection of credit institutions (French): https://www.bcl.lu/fr/cadre_juridique/documents_nationaux/circulaires_bcl/_circulaires/2014/Circulaire_2014_235/Circulaire_BCL_2014-235.pdf
• Circular BCL 2021/244 of 10 February 2021, Modification of the statistical reporting from credit institutions: https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Regle_circs_lettres-circs/Circulaires/BCL_2021_244.pdf
• BCL, Circulars for credit institutions (in force and repealed or obsolete): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Regle_circs_lettres-circs/Circulaires/index.html
• BCL circular letter ST.24-0013, Monitoring compliance with statistical reporting (15 January 2024): https://www.bcl.lu/en/Regulatory-reporting/Etablissements_credit/Statistiques-bancaires-et-monetaires/Regle_circs_lettres-circs/Lettres_circulaires/ST_24_0013_Monitoring_compliance_with_stat_reporting.pdf
• Law of 23 December 1998 on the monetary status and the Banque centrale du Luxembourg, as amended (Article 32): https://legilux.public.lu/eli/etat/leg/loi/1998/12/23/n1/jo
• Regulation (EU) No 1071/2013 of the ECB (ECB/2013/33) on the balance sheet of the MFI sector (recast): https://eur-lex.europa.eu/eli/reg/2013/1071/oj
• Regulation (EU) No 1072/2013 of the ECB (ECB/2013/34) on MFI interest rate statistics (recast): https://eur-lex.europa.eu/eli/reg/2013/1072/oj
• Regulation (EU) 2021/379 of the ECB (ECB/2021/2) on the balance sheet items of credit institutions and of the MFI sector (recast): https://eur-lex.europa.eu/eli/reg/2021/379/oj
• Regulation (EU) No 1409/2013 of the ECB (ECB/2013/43) on payments statistics: https://eur-lex.europa.eu/eli/reg/2013/1409/oj
• Regulation (EU) 2020/2011 of the ECB (ECB/2020/59) amending Regulation (EU) No 1409/2013 on payments statistics: https://eur-lex.europa.eu/eli/reg/2020/2011/oj
• CSSF, Prudential reporting for credit institutions: https://cssf.lu/en/prudential-reporting-credit-institutions
• Regulation (EU) 2022/1917 of the ECB (ECB/2022/31) on infringement procedures in cases of non-compliance with statistical reporting requirements: https://eur-lex.europa.eu/eli/reg/2022/1917/oj
• Circular CSSF 26/908 of 25 March 2026, amending Circular CSSF 18/703 on the semi-annual reporting of borrower-related residential real estate indicators (with the consolidated circular annexed): https://www.cssf.lu/wp-content/uploads/cssf26_908eng.pdf
• ECB press release, ECB announces main milestones for roll-out of Integrated Reporting Framework (8 June 2026): https://www.ecb.europa.eu/press/pr/date/2026/html/ecb.pr260608~6766ec7154.en.html
• BCL, Project: Integrated Reporting Framework (IReF): https://www.bcl.lu/en/Regulatory-reporting/IREF/index.html

Preparing the next S 3.2 file

The next S 3.2 rests on three artifacts. The first is a loan extract: every house-purchase loan granted to a household in the half-year for a property in Luxembourg, with each loan’s own LTV, from which the unweighted average is taken. The second is an account inventory at the period-end date: every non-MFI overnight deposit account, flagged for transferability and for internet or PC access, and reconciled to the S 1.1 overnight deposit lines for the same month-end. The third is a short memo recording the BCL’s answers on the points its documents leave open. With those three in hand, the June file goes to the BCL through Sofie or e-file by 20 July and the December file by 20 January, or by the date the BCL’s calendar for that year sets.

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