TPTBH Reporting: TPTBHR, TPTBHN and the BCL’s EUR 10bn Custody Test
Every credit institution resident in Luxembourg sends the Banque centrale du Luxembourg (BCL) a monthly TPTBHR file listing, security by security, what it holds in custody for resident customers, no later than 20 calendar days after the month ends. TPTBH reporting has a second leg. A bank whose securities held for non-resident customers reach EUR 10 billion also files TPTBHN, within 25 working days, and every other bank sends an aggregated Excel return on its 31 December non-resident custody positions within two months. The legal root is ECB Regulation (EU) No 1011/2012 on statistics on holdings of securities, which the BCL applied to non-resident custody through Circular BCL 2013/233 of 20 June 2013.
The BCL hub groups the reports under TPTBH, its security-by-security report on off-balance sheet data, and both monthly reports have been mandatory in Layout 2 since the December 2014 reference period. The difficulty is classification. Each holding sits on off-balance sheet item 3-003000, split by the customer’s institutional sector (and, for TPTBHN, country); every security without a valid ISIN needs a block of static data; and one threshold decides whether non-resident custody goes in as monthly XML or one annual spreadsheet.
Related reading: S 0.1 Daily Deposit Report: The BCL’s Mid-Month and Month-End Return
| Filing | Who files | Reference date and deadline | Format |
|---|---|---|---|
| TPTBHR (resident customers) | All resident credit institutions | Month-end; within 20 calendar days | XML, Layout 2 |
| TPTBHN (non-resident customers) | Credit institutions holding EUR 10 billion or more for non-resident customers | Month-end; within 25 working days | XML, Layout 2 |
| Annual questionnaire (OTXREP-TPTBNR file) | Credit institutions not subject to monthly TPTBHN | 31 December; within 2 months | Excel template, aggregated |
Legal basis of TPTBH reporting: ECB/2012/24 and two BCL circulars
The European instrument is Regulation (EU) No 1011/2012 of the European Central Bank of 17 October 2012 concerning statistics on holdings of securities (ECB/2012/24), OJ L 305 of 1 November 2012. Article 2(1) puts resident custodians in the actual reporting population, and Article 1 defines a custodian as a financial corporation that safekeeps and administers financial instruments for the account of clients. Annex I sets out three custody data sets:
- Part 3: securities with an ISIN held for resident non-financial investors and for financial investors that do not report their own holdings.
- Part 4: securities with an ISIN held for non-financial investors resident in other euro area Member States.
- Part 5: securities with an ISIN issued by euro area residents and held for investors in non-euro area Member States or outside the Union.
Delivery mechanics are left to the national central bank. Article 6b(1) requires each national central bank to decide by when it needs to receive data from reporting agents to perform quality checks and meet ECB deadlines. Article 7(2) requires national central banks to define national reporting arrangements and decide whether custodians must report security-level data investor by investor. Article 4(5)(b) is the source of the EUR 10 billion split: NCBs may partially or fully exempt custodians from the non-resident custody requirements of Article 3(2)(b) and (c) where the securities they hold for all non-resident clients total less than EUR 10 billion. Amendments since 2012 include Regulation (EU) 2015/730 (ECB/2015/18) and Regulation (EU) 2016/1384 (ECB/2016/22), which kept that derogation.
Circular BCL 2013/233 of 20 June 2013, addressed to all credit institutions, implements the non-resident side in Luxembourg. The BCL chose the approach it already used for banks’ own holdings: monthly security-level positions, from which it derives valuation effects and financial transactions itself. The circular adopts the EUR 10 billion exemption and requires exempted banks to report non-resident custody annually on an aggregated basis. It called the monthly report “BNR”; the hub now publishes it as TPTBHN Layout 2.
Circular BCL 2019/242 of 28 January 2019 describes TPTBHR as the indirect collection the BCL set up through banks under Regulation ECB/2012/24 for resident customers that are not themselves subject to statistical collection, reported since 2014.
Behind both circulars sits Article 32(1) of the amended Law of 23 December 1998 on the monetary status and the Banque centrale du Luxembourg, which empowers the BCL to collect the statistical information its tasks require, directly from economic agents if needed, and to verify it on site. The TPTBH documents do not cite Article 32, so that link is an interpretation. The obligation runs to the BCL as central bank: the CSSF appears in the TPTBH documents only as the issuer of the identification number used in file names and declarant IDs. The TPTBH instructions and compendia also state that the French text prevails.
Who must report TPTBHR and TPTBHN: every resident bank, then a EUR 10 billion split
TPTBHR has the simplest scope. Section 1.1 of the January 2019 instructions says the report “must be provided by all resident credit institutions regardless of their legal status”. There is no size threshold. The instructions do not say whether a month with nothing to report needs a file, and no BCL statement on nil returns for TPTBH was found in the sources reviewed.
TPTBHN starts from the same population and narrows it to credit institutions “for which the total amount of the assets held by their non-resident customers is higher than or equal to 10 billion euros”. Circular 2013/233 adds a timing rule: a bank has to start submitting once the securities it holds for non-resident clients exceed EUR 10 billion during three consecutive months. The BCL selects monthly reporters once a year from the annual data and informs exempted banks by separate letter.
The annual questionnaire covers everyone else. The 2026 remittance calendar repeats the rule in a footnote: the annual report “should only be submitted by credit institutions that are not subject to the monthly TPTBHN reporting requirements”. Each bank files exactly one of the two non-resident products.
Three scope points are easy to misread:
- The EUR 10 billion test measures securities held for non-resident customers. The bank’s balance sheet total and its resident custody book play no part in it.
- Neither the instructions nor the circular state the valuation basis for the test. The monthly reports value quoted securities at market price, but the threshold text is silent, so a bank near the line has a judgement to document.
- The trigger is worded differently in the two texts: “higher than or equal to” in the instructions, “superior to … during three consecutive months” in the circular. Where a bank sits close to EUR 10 billion, the BCL is the party that resolves the difference.
The report is filed per credit institution. The instructions contain no consolidation rule and no separate branch treatment; residence follows the BCL’s “Definitions and concepts for the statistical reporting of credit institutions”. Third-country customers have no special regime: TPTBHN takes every non-resident customer, coded by ISO country.
The BCL distinguishes the reporter transmitting a file from the declarant whose positions are reported. Its electronic-transmission manual provides a reporter identifier for professionals of the financial sector. This technical arrangement supports third-party transmission, but does not itself establish the contractual conditions for delegation or transfer the declarant’s reporting obligations.
What the report contains: one off-balance sheet line per customer sector, then security-level fields
Each TPTBH file has a header and a set of reported lines. The header carries the end-of-month date, the closing date, the reporter and declarant identifications and the reporting currency; the example file in the schema package sets the layout to 2. Every line is a key built from sub-table 3, item 003000 (“securities held on behalf of customers” in the BCL definitions), the holder’s country, the currency placeholder XXX and the holder’s sector code. The securities sit inside each line, and each line closes with totalReportedAmount, which must equal the sum of its securities’ reportedAmount values.
The lines in TPTBHR
TPTBHR fixes the country at LU. Eight lines are mandatory: central government (11000), state government (12100), local government (12200), social security funds (12300), non-financial corporations (21000), households split into sole proprietors (22110) and physical persons (22120), and non-profit institutions serving households (22200). Line 3-003000-LU-XXX-11000, for example, carries securities held for Luxembourg central government.
Six lines are accepted but not mandatory: central counterparties (42200), other financial intermediaries (42900), financial auxiliaries (43000), captive financial institutions and money lenders (44000), insurance corporations (45000) and pension funds (46000). Holdings of customers that report their own securities are excluded: the BCL (31000), credit institutions (32100), other deposit-taking corporations (32200), money market funds (33000), non-MMF funds (41000) and securitisation vehicles (42100).
The lines in TPTBHN
TPTBHN puts the holder’s ISO country code in the line key, with LU and XX (“no breakdown”) excluded, and covers non-resident customers “regardless of the economic sector”. The line table runs through all twenty sectors from central government (11000) to pension funds (46000), central banks, credit institutions and funds included. Line 3-003000-DE-XXX-22120 holds securities kept for households resident in Germany. The codes are the BCL’s own five-digit sector nomenclature; for a contrast with another central bank’s approach, see our note on Bundesbank customer classification under RS-57.
Security-level fields
The ISIN takes priority over any other identifier. A security with a valid ISIN is reported with codeType 1 and needs little else; one without takes codeType 2, an internal or external code (a CUSIP, for instance) and a full set of supplementary data.
| Field group | With an ISIN (codeType 1) | Without an ISIN (codeType 2) |
|---|---|---|
| Identification | ISIN in code | Reporting agent’s code, name, currency of the security |
| Issuer | Not reported | Country and sector of the issuer |
| Every security | holdSecurityType, reportedAmount | holdSecurityType, reportedAmount, securityType |
| Quantity | nominalAmount and nominalCurrency if quoted in percent; numberOfUnits if quoted in currency | Same rule |
| Debt only | Not reported | issueDate, finalMaturityDate, poolFactor, couponType, couponFrequency, couponLastPaymentDate, couponRate |
Security types for non-ISIN securities are F.3 debt securities, F.511 quoted shares, F.512 unquoted shares, F.519 other equity and F.52 investment fund shares or units. The templates note that debt securities are usually quoted in percent and equity in currency, which decides whether quantity is nominal capital or a number of units.
The holding type separates economic ownership from physical custody:
| Code | Holding type | Who counts as holder |
|---|---|---|
| 01 | Held, not affected by a temporary transfer | The customer |
| 02 | Securities lent | The lender stays the holder |
| 03 | Sold in a repurchase agreement | The repo seller stays the holder |
| 05 | Short sales | Flagged separately to avoid double counting |
A securities borrower, or a buyer under a repurchase agreement, is not treated as the holder.
Units, valuation, sign and rounding
Amounts are in the accounting currency of the balance sheet, with enough decimals for totals to match the exact sum of the security amounts; the XML schema accepts up to five decimal places. As a rule, quoted securities are valued at the stock exchange price at the end of the reporting date; debt securities must be valued at the dirty price, accrued interest included. Nominal capital is reported without applying the pool factor, and trading lots are ignored: where the quantity is a number of units, it counts individual securities.
The compendium requires every reportedAmount to be zero or positive. This implies that a short position is identified by holding type 05, with no negative amount anywhere in the file. Coupon rates are annualised percentages, so a 5.5% coupon goes in as 5.5 (the instructions print it with a decimal comma, 5,5).
The annual questionnaire
The Excel template TPTBNR_Annual_Quest.xls has three sheets: instructions, explanations with examples, and aggregated data. Its variables are the declarant ID (the CSSF number), security type, country and sector of the holder, reported amount, period, and country and sector of the issuer. Aggregate country codes X1 to X6, the country code XX and sector code 90000 are not allowed, and amounts are in the accounting currency. Circular 2013/233 adds that instrument types follow the codes of the BCL’s balance sheet security-by-security report.
Deadlines for TPTBH reporting: 20 calendar days, 25 working days and the two-month annual window
Both monthly reports take the last day of each month as their reference date “in principle”, the phrase both sets of instructions use. TPTBHR is due no later than 20 calendar days after the end of the reference period, TPTBHN no later than 25 working days after it. The annual questionnaire reports positions at 31 December and is due within two months. As a rule of thumb, a month’s TPTBHR is due by the twentieth calendar day of the following month, and its TPTBHN about five weeks after month-end.
The binding dates sit in the BCL’s yearly remittance calendar, whose footnote says its deadlines are based on the working days defined by the ECB for the transmission of statistics by national central banks. The 2026 edition shows how the rules land:
- January 2026 reference period: TPTBHR due 20 February 2026, TPTBHN due 6 March 2026.
- May 2026: TPTBHR due 22 June 2026. The twentieth fell on a Saturday, and the calendar moved the date to the following Monday.
- December 2026: TPTBHR due 20 January 2027, TPTBHN due 5 February 2027, the annual non-resident return due 1 March 2027.
The same calendar marks the TPTBHN dates for the July to December 2026 reference periods with an asterisk: “The following deadlines may change during the year 2026”. It gives no reason, and the TPTBHR column carries no such flag, so a production plan built on those TPTBHN dates needs the current version of the calendar.
First reference dates explain the old document dates on the hub. Article 10 of Regulation 1011/2012 started reporting with the December 2013 reference period; under Circular 2013/233, the first monthly non-resident data were due by 5 February 2014 and the first annual return by 27 February 2014. To pick the first monthly reporters, every bank reported its end-June 2013 non-resident custody by 31 July 2013.
Another clock runs after submission. The BCL’s April 2025 feedback document says each data-quality or ad hoc feedback carries its own response deadline, set by urgency, and that meeting it falls within the ECB’s non-compliance framework.
Submission of TPTBH files: XML schema 1.4, SOFiE or e-file, and the OTXREP spreadsheet
TPTBHR and TPTBHN travel as XML, and the hub publishes XML schemas for them, no XBRL taxonomy. The schema packages on the hub (TPTBHR_L2_XML.zip and TPTBHN_L2_XML.zip, listed with an update date of 7 October 2015) contain version 1.4 of the BCL’s security-by-security schema, namespace www.bcl.lu/2007/SBS. The root element SBS holds the header and one data block, BHR or BHN, and its version attribute is fixed at 1.4.
The BCL’s “Manual of electronic transmission for statistical reports of credit institutions” (February 2021) sets the file names:
- TPTBHR_L2_yyyymm_Rrrrrrrrrr_Dddddddddd_yyyymmdd_nnn, and the same pattern starting TPTBHN_L2 for the non-resident report.
- yyyymm is the reference month; R is the reporter letter (B for a bank, P for a professional of the financial sector) and D the declarant letter (B, because the declarant is a bank); each is followed by the nine-digit CSSF number padded with leading zeros.
- yyyymmdd is the creation date and nnn a sequence that restarts at 001 each day; 000 is not allowed.
The example in the schema package, TPTBHR_L2_201401_B000000999_B000000999_20140204_001.xml, is the first file created on 4 February 2014 by bank 999 for its own January 2014 data. In its header the bank appears as reporterID and declarantID with type 23, the manual’s code for bank CSSF numbers (type 32 covers professionals of the financial sector).
The manual lists SOFiE and e-file as accepted channels and leaves room for other secure channels agreed with the BCL. E-mail is out: BCL circular letter ST.24-0013 of 15 January 2024 says the BCL no longer accepts statistical reports by e-mail.
Official filing resources for the annual return
Circular BCL 2013/233 specifies an annual Excel submission through SOFiE’s OTX channel or e-file, with a prescribed filename containing OTXREP and TPTBNR: the name is OTXREPB0nnn-TPTBNR_20131231_B0nnn_yyyymmdd_001.xls, where nnn is the bank’s CSSF number. The instruction sheet in the current template gives a different pattern, OTXREP-B0nnn-TPTBHN_yyyymmdd_B0nnn_yyyymmdd_001.xls, and still mentions CD-ROM. The two BCL documents disagree on the report code inside the name and neither has been withdrawn, so the name is a question for the BCL before the first annual run. The CD-ROM mention predates the 2024 secure-channel rule, and I would not treat it as a live option.
Corrections and resubmission
The TPTBH instructions contain no resubmission procedure. The transmission manual’s daily sequence number distinguishes files sent on the same day, and the BCL’s April 2025 feedback document lists three feedback types for TPTBHR and TPTBHN among other reports: FL-OK or FL-NOK on whether a file was processed or contained technical errors, DQ-FDB on data points needing correction or confirmation, and ADHC-FDB for requests outside the production cycle. Under Circular BCL 2021/243 these feedbacks move from e-mail to SOFiE and e-file in stages, as files named FDBBUSI. The BCL runs the same channel-based model for AnaCredit, covered from the technical side in our AnaCredit v1.0.15 schema update note.
Validation rules for TPTBHR and TPTBHN: 22 permanent checks and the schema gaps
Each report has a “Compendium of verification rules” dated November 2017. Both say the reports are subject only to internal checks, split into permanent rules, which software providers are invited to build in, and temporary rules addressed to reporting agents. The compendia give the reason for the rigour: the ECB checks the data before aggregating them with those of other Member States.
| Rules | What they check |
|---|---|
| 1 | Only authorised lines are used (fourteen LU lines in TPTBHR, twenty sector lines per country in TPTBHN) |
| 2 to 4 | reportedAmount is zero or positive; a positive amount needs a positive nominal (percent-quoted) or unit count (currency-quoted) |
| 5 | ISINs meet ISO 6166, including check digit and a valid prefix |
| 6, 7, 10 to 12 | Issuer country, issuer sector and security type for non-ISIN securities; F.52 only with sectors 33000 or 41000, which F.511 and F.512 may not use |
| 8, 9 | Holding type is 01, 02, 03 or 05; nominal currency is ISO 4217, excluding XX1 to XX4 and XXX |
| 13 to 22 | Debt static data: issue date not after the closing date, pool factor above zero, coupon codes, zero-coupon pairing, coupon dates and rates |
Rule 5 goes beyond the check digit. The first two characters must be an ISO 3166 country code valid at the issue date, or EU, XA, XB, XC, XD or XS; prefixes such as DU, EV, HF, HS, QS, QT, QU, QY, TE, XF, XX and ZZ do not make a valid ISIN. The instructions add that provisional or pseudo ISINs, and internal codes built to look like ISINs, are reported as codeType 2.
Rule 19 depends on the last coupon payment date, which changes at every coupon. The gap between the closing date and the last coupon payment date must fit the declared coupon frequency, with windows set at twice the coupon period to allow for an irregular first coupon: under 720 days for annual coupons, 360 for semi-annual, 180 for quarterly, 124 for bi-monthly, 62 for monthly and 31 for fortnightly.
The single temporary rule allows sector code 12100 (state government) only with the country code of a country with a federal structure. The compendium does not say which fields it targets; since TPTBHR itself has a mandatory LU line for sector 12100, the likely target is the issuer country and sector of non-ISIN securities.
A schema-valid file can still fail the BCL checks, and the gaps are specific:
- The shared SBS datatype schema enumerates holding type 04, “securities issued”, which rule 8 does not allow in TPTBH.
- The schema accepts a pool factor of 0; rule 14 requires a value above zero, with a default of 1 where no pool factor applies.
- The line key requires XXX as currency placeholder, while rule 9 rejects XXX as a nominal currency.
The transmission manual states the principle behind these gaps: the schema constrains formats but does not necessarily check that a well-formed code is valid. A file that passes the XSD can still come back with FL-NOK or DQ-FDB feedback.
Caveats and interactions: voluntary sectors, threshold drift and the overlap with TPTBB
The voluntary TPTBHR lines are a real choice: sending insurance or pension fund holdings is accepted, and leaving them out is compliant. One inconsistency is worth knowing. The instructions’ list of excluded customers names five of the six optional sectors, while central counterparties (42200) appear only among the accepted lines. Circular 2019/242 resolves it by listing central counterparties among the sectors no longer collected from 1 April 2019, so all six are optional.
The exclusions follow the ECB regulation’s design: Part 3 of Annex I asks custodians about resident financial investors only where those investors do not report their own holdings. TPTBHN has no equivalent exclusion, and comparing the texts, the BCL’s non-resident collection is wider than the regulation’s minimum. Part 4 covers only non-financial investors in other euro area Member States, Part 5 only euro area securities held for investors outside the euro area, and both only securities with an ISIN; TPTBHN takes every customer sector, every issuer and non-ISIN securities. Article 7(2) leaves arrangements to NCBs, and the BCL documents do not explain the wider scope. On investor-by-investor reporting, the other lever Article 7(2) offers, the BCL chose sector-and-country lines.
Own holdings go to TPTBB, the BCL’s security-by-security report on balance sheet data (TPTBBL monthly and TPTBBN quarterly in the 2026 calendar), while TPTBH covers item 3-003000, securities held on behalf of customers. Holding types keep temporary transfers on the right side: a customer’s lent or repo’d securities stay on that customer’s TPTBH line under codes 02 or 03.
Tax reporting is a separate regime. Our CRS reporting guide for Luxembourg covers the account-level tax return; nothing in the TPTBH instructions or circulars connects the two, and TPTBHN never identifies an investor, only a country and a sector.
Data quality carries formal consequences. Circular letter ST.24-0013 states that Regulation (EU) 2022/1917 (ECB/2022/31) on infringement procedures applies from 30 April 2024 to BCL collections under Regulation 1011/2012, among others; that from the April 2024 reference period the ECB and the BCL monitor compliance with the minimum standards for transmission, accuracy and concepts; and that, for non-compliance with those minimum standards, the ECB may impose sanctions not exceeding EUR 200,000 after an infringement procedure. Serious misconduct is also recorded, and the ECB may impose sanctions for it; outside serious misconduct, a remedial plan is possible once a warning has been issued and an accumulation threshold for alleged infringements has been reached. For custody data, ECB Decision (EU) 2022/1921 (ECB/2022/32) says in its recitals that the total value of securities deposited with the custodian is a more appropriate size measure than total assets when a sanction is calculated.
The annual return has two document gaps worth a line in any procedures manual. The template marks issuer country and issuer sector as “not mandatory”, while Circular 2013/233 lists them among the aggregation keys, and the two documents give different file names.
Changes to TPTBH reporting: the 2019 sector cut, a flagged 2026 calendar and IReF milestones
The TPTBH documents change rarely, which is why many dates on the hub look old:
- December 2014 reference period: TPTBHR and TPTBHN Layout 2 become mandatory. The TPTBHN instructions in force are dated January 2014 (hub date 28 November 2014).
- 2015 and 2016: Regulations (EU) 2015/730 and 2016/1384 amend the ECB regulation. The 2016 text splits debt into F.31 and F.32 and fund shares into F.521 and F.522; the TPTBH instructions and compendia keep F.3 and F.52 without comment.
- 7 October 2015: hub date of the XML schema packages. November 2017: the current verification compendia.
- 28 January 2019: Circular BCL 2019/242 waives, from 1 April 2019, resident holdings in six financial sectors because the BCL now collects them directly. The revised TPTBHR instructions (January 2019, hub date 7 February 2019) turn those lines optional. The same circular moved the S 0.1 deposit report from daily submission to submission every 15 days.
- 10 February 2021: Circular BCL 2021/244 updates the BCL’s “Definitions and concepts for the statistical reporting of credit institutions” following Regulation ECB/2021/2, adding country codes for positions with the EFSF and the SRM and changing the sector classification of supranational institutions. It lists TPTBHR among the reports affected, together with the non-resident report that it codes TPTBNR under the TPTBHN title (security by security report, off-balance sheet data, non-resident customers). Reporting under the changes is mandatory from the January 2022 deadline, with the first reports relating to the end of January 2022.
- 15 January 2024: circular letter ST.24-0013 brings TPTBH under Regulation (EU) 2022/1917 monitoring.
- April 2025: the BCL feedback document adds TPTBHN and TPTBHR to the staged move of feedbacks onto SOFiE and e-file.
- December 2025: the 2026 calendar flags the July to December 2026 TPTBHN deadlines as subject to change.
The larger change is still a plan. On 8 June 2026 the ECB announced milestones for its Integrated Reporting Framework (IReF): a public consultation on the draft IReF Regulation in the second half of 2027, a one-year pilot from the second quarter of 2030, and first official IReF reporting in the second quarter of 2031, followed by a one-year parallel phase in which existing statistical reporting within the IReF’s scope continues. The ECB makes the timeline subject to adoption of the regulation after the consultation.
The ECB’s November 2024 IReF overview confirms that the planned initial framework includes the SHS-S requirements for banks acting as custodians. The SHS-S legal basis is Regulation (EU) No 1011/2012. The overview does not identify Luxembourg’s TPTBHR or TPTBHN files by name, so the final treatment of those returns, any national data requirements and migration arrangements remains dependent on the adopted IReF Regulation and national implementation plan.
Frequently Asked Questions
Our bank entrusts customer securities to a sub-custodian for a lending programme and cannot tell how many are on loan at month-end. Which holding type applies?
The instructions settle it: where securities are entrusted to another custodian for securities lending and the quantity lent is not precisely known, all of them are reported with holding type 02, “securities lent”.
A bond held for a customer has only a provisional ISIN at month-end. How does it go in?
As a security without an ISIN: codeType 2, the provisional or internal code in the code field, plus name, currency, issuer country and sector, security type F.3 and the full debt block. The instructions rule out codeType 1 for provisional and pseudo codes.
What goes in finalMaturityDate for a perpetual bond?
The instructions prescribe 01.01.2999. Fixed defaults apply to the pool factor too: 1 for a debt security repaid only at maturity or where no pool factor applies.
A non-ISIN bond has never paid a coupon. What is its last coupon payment date?
The issue date. Rule 19 still compares the closing date with that date and the declared coupon frequency, so a bond issued long ago with a short declared frequency will be flagged.
Do we report trading lots or individual securities when a share trades in lots of 100?
Individual securities. The instructions exclude the market trading lot from the quantity, so numberOfUnits counts single shares.
If our non-resident custody falls below EUR 10 billion, can we stop TPTBHN the following month?
The documents do not provide for a month-to-month exit. Under Circular 2013/233 the BCL selects monthly reporters once a year and informs exempted banks by letter, so a bank on the monthly list appears to stay there until the BCL says otherwise.
Which language version governs if the English and French instructions differ?
The French text. The TPTBH instructions, the verification compendia and Circular 2013/233 all carry that notice.
Related Articles
- S 0.1 Daily Deposit Report: The BCL’s Mid-Month and Month-End Return: the BCL deposit return whose frequency the same 2019 circular changed.
- AnaCredit v1.0.15: BCL Swaps the NUTS 3 Code List for January 2027: a recent BCL technical-specification change for the granular credit collection.
- Bundesbank Customer Classification in 2026: RS-57 sFEU Update and NACE Rev. 2.1: how the German central bank organises customer sector coding for MFI statistics.
- CRS Reporting in Luxembourg: the account-level tax reporting regime for Luxembourg financial institutions.
- BCL Financial Stability Review 2026: The Luxembourg Risk Map: the BCL’s 2026 assessment of risks in the Luxembourg financial sector.
Key Takeaways
- Code every custody client to a BCL sector before month-end: the code alone decides whether a resident holding is mandatory, optional or excluded from TPTBHR.
- Measure securities held for non-resident customers against EUR 10 billion every month; three consecutive months above it brings monthly TPTBHN under Circular 2013/233.
- Build validation from the November 2017 compendia and use the XSD only as a format check.
- Take each year’s binding dates from the BCL remittance calendar, never from the day counts alone.
- Get the BCL’s written answer on the annual file name and the optional issuer fields before the 31 December return.
- Follow the BCL’s notified feedback arrangements for each report. Its April 2025 instructions provide for a staged migration of FL-OK/FL-NOK, DQ-FDB and ADHC-FDB feedback to SOFiE and e-file, with advance notification by report type. Meet the response deadline specified in each feedback.
- Include TPTBH reporting in the IReF impact assessment now: the ECB already identifies banks’ custodian-related SHS-S requirements within the planned framework. Track the second-half 2027 consultation and subsequent national implementation material to determine the final treatment of Luxembourg’s returns.
Sources and References
- BCL, TPTBH hub page (instructions, reports, compendia, XML schemas, annual questionnaire): bcl.lu TPTBH page
- BCL, TPTBHR instructions, Layout 2 (January 2019): PDF; revision-marked: PDF
- BCL, TPTBHN instructions, Layout 2 (January 2014): PDF
- BCL, report templates: TPTBHR_L2_report_EN.xls; TPTBHN_L2_report_EN.xls
- BCL, compendia of verification rules (November 2017): TPTBHR; TPTBHN
- BCL, XML schema packages, version 1.4: TPTBHR_L2_XML.zip; TPTBHN_L2_XML.zip
- BCL, annual questionnaire on assets held on behalf of non-resident third parties: TPTBNR_Annual_Quest.xls
- Circular BCL 2013/233 of 20 June 2013: PDF
- Circular BCL 2019/242 of 28 January 2019: PDF
- Circular BCL 2021/244 of 10 February 2021: PDF
- BCL, circulars for credit institutions: bcl.lu circulars page
- BCL circular letter ST.24-0013 of 15 January 2024: PDF
- BCL, Manual of electronic transmission for statistical reports of credit institutions (February 2021): PDF
- BCL, Definitions and concepts for the statistical reporting of credit institutions (July 2024): PDF
- BCL, Feedbacks for the statistical reports (April 2025): PDF
- BCL, calendar of remittance dates for credit institutions in 2026: PDF; calendars page
- Law of 23 December 1998 on the monetary status and the Banque centrale du Luxembourg, consolidated 30 July 2021 (Article 32): PDF (FR)
- Regulation (EU) No 1011/2012 (ECB/2012/24): EUR-Lex
- Regulation (EU) 2015/730 (ECB/2015/18): EUR-Lex
- Regulation (EU) 2016/1384 (ECB/2016/22): EUR-Lex
- Regulation (EU) 2022/1917 (ECB/2022/31) on infringement procedures for statistical reporting: EUR-Lex
- Decision (EU) 2022/1921 (ECB/2022/32) on the methodology for calculating sanctions: EUR-Lex
- ECB press release, “ECB announces main milestones for roll-out of Integrated Reporting Framework” (8 June 2026): ecb.europa.eu
- ECB, The Eurosystem Integrated Reporting Framework: an overview (November 2024): ECB IReF overview (PDF)
- BCL, Project: Integrated Reporting Framework (IReF): bcl.lu IReF page
Running the Next TPTBH Month-End
TPTBH reporting turns on three settings: the sector code on each custody client, the bank’s position against the EUR 10 billion non-resident threshold, and the static data on every security without a valid ISIN. Before the next month-end file goes out through SOFiE or e-file, the artefact to produce is a validation pack built from the November 2017 compendia and run against the full file, with the TPTBHR date taken from the BCL calendar for the month concerned.
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