EBA Pushback on Commission Operational Risk RTS: What It Means for CRR3 Reporting
The EBA objects to two Commission amendments on operational risk RTS under CRR3. What changed, what it means for reporting teams, and how to prepare.
The EBA objects to two Commission amendments on operational risk RTS under CRR3. What changed, what it means for reporting teams, and how to prepare.
Last updated: April 2026 DORA (Regulation (EU) 2022/2554) has been live since 17 January 2025. For Luxembourg fund administrators, UCITS management companies, and AIFMs, the question is no longer whether it applies to you. It does. The question is whether your implementation actually covers what the CSSF expects, or whether you have gaps disguised as…
Last updated: April 2026 Miss a COREP remittance by one day and the CSSF will notice. Miss a CRS filing deadline and the ACD will notice even faster. Q2 is the quarter where annual filings, quarterly prudential reports, and ongoing transaction reporting obligations all converge on the same teams, often the same individuals, at the…
Last updated: April 2026 Get a board appointment wrong in Luxembourg and the CSSF will tell you to fix it. That conversation is not one any institution wants to have, and under the proposed updated suitability guidelines, the scope of what “wrong” looks like just got wider. The joint ESMA-EBA consultation paper (ESMA35-243228190-8034 / EBA/CP/2026/03),…
Last updated: April 2026 Your COREP templates are filed on time. Your LCR and NSFR ratios are above the minimum. Your Pillar 3 disclosures are published. Then the CSSF sends a letter asking for your ICAAP/ILAAP documentation as part of the SREP cycle, and the room goes quiet. Because unlike the quantitative reports, ICAAP and…
Last updated: March 2026 If you work in reporting at a Luxembourg bank, fund manager, or insurance company, the CSRD has probably been on your radar since 2023. You may have started a gap analysis. You may have budgeted for an ESG data platform. And then the Omnibus hit, the scope shrank by roughly 80%,…
Last updated: March 2026 If you run regulatory reporting for a third-country branch in the EU, your reporting workload is about to change substantially. For the first time, the EBA has published a harmonised set of reporting templates specifically designed for third-country branches (TCBs). The first reporting reference date is 31 March 2027. That is…
Last updated: March 2026 Your institution has three loan facilities to three different Luxembourg companies. Different names, different sectors, different NACE codes. Each facility is well below the 25% large exposure limit. Then a supervisor asks you to explain why all three companies share the same ultimate beneficial owner, depend on the same revenue source,…
Last updated: March 2026 Your LCR is 142%. The NSFR is 108%. Both are comfortably above the 100% minimum. Then the supervisor asks why your C 67.00 shows that a single counterparty provides 23% of your wholesale funding, why the maturity ladder in C 66.01 shows a cliff in the 3-month bucket, and why the…
Last updated: March 2026 Rates went up faster than most banks modelled. Between mid-2022 and late 2023, the ECB raised its deposit facility rate from -0.50% to 4.00%, a shift of 450 basis points in under 18 months. For Luxembourg banks that had built fixed-rate asset portfolios during the low-rate era, financed by short-term or…