CSSF Circular 25/880 on payment service user relationships and PSP ICT assessment.

Who is concerned?

This circular is broken down into 3 sections analysed one by one, each with the official text and Luxgap practical guidance for compliance in Luxembourg.

Key obligations

CSSF expectations for PSP customer relationships and ICT self-assessment, in the wake of DORA.

Luxgap supports CSSF-supervised entities (banks, PFS, payment and e-money institutions, management companies, funds) in complying with this circular: gap analysis, policy and register updates, CSSF inspection readiness, articulation with the DORA Regulation and the NIS 2 framework where relevant.

Deadlines

See the official CSSF text for precise application dates. Most recent ICT circulars articulate with the DORA Regulation, applicable since 17 January 2025.

Sanctions for non-compliance

Non-compliance exposes entities to CSSF administrative sanctions: injunctions, pecuniary sanctions, restrictions or suspension of authorisation.

How Luxgap helps

CSSF expectations for PSP customer relationships and ICT self-assessment, in the wake of DORA.

Luxgap supports CSSF-supervised entities (banks, PFS, payment and e-money institutions, management companies, funds) in complying with this circular: gap analysis, policy and register updates, CSSF inspection readiness, articulation with the DORA Regulation and the NIS 2 framework where relevant.