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Compliance · CSSF circular

CSSF Circular 25/881 amending CSSF 20/750 on ICT and security risk management.

Aligning the foundational 20/750 circular (ICT risks) with the DORA Regulation.

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Who is concerned?

This circular is broken down into 4 sections analysed one by one, each with the official text and Luxgap practical guidance for compliance in Luxembourg.

Key obligations

Aligning the foundational 20/750 circular (ICT risks) with the DORA Regulation.

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

Aligning the foundational 20/750 circular (ICT risks) with the DORA Regulation.

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.

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