How to comply with article M.6 of CSSF 25/881?

Question

I need to bring my Luxembourg organisation into compliance with article M.6 of CSSF 25/881 (CSSF 25/881). What are the concrete requirements, the sanctions, and how can Luxgap support me?

Accepted Answer

The classic trapArticle M.6 looks harmless: an entry-into-force clause and a list of signatories. The real trap lies elsewhere. The CSSF states that the circular applies with immediate effect, with no transition period. Many financial entities assume an implicit adaptation window exists: it does not. Another major trap, the annex refers to a consolidated text of CSSF 20/750 that has since been further amended by Circular CSSF 26/915. Entities working from an outdated version of the 20/750 baseline, or from the English version alone which is not consolidated, apply obsolete ICT requirements and risk a compliance gap during a CSSF inspection.The trap of the applicable version and immediate effectImmediate effect: no grace period, the CSSF may check DORA alignment from entry into force.The text actually enforceable is the consolidated version of CSSF 20/750, incorporating Circulars 22/828, 25/881 and then 26/915.Documented language divergence: the English PDF is not consolidated by 26/915 and additionally names branches in Luxembourg of PSP incorporated in a third country, while the French version does not.Working from a PDF downloaded once fixes a snapshot that becomes wrong with every new amending circular.The exact scope of covered entities may differ depending on the language version chosen: the choice of reference is not neutral.ICT compliance does not depend on the text you read, but on the text currently in force. An unversioned documentary baseline is a silent source of non-compliance.How Luxgap automates this riskOur Luxgap Regulatory Version Sentinel makes it impossible to work from an outdated version of a CSSF text. The tool continuously monitors the CSSF and DORA regulatory corpus, detects each amending circular as soon as it is published, and automatically rebuilds the enforceable consolidated version, flagging divergences between the French and English versions.Monitors CSSF publications in real time and rebuilds the full consolidation chain (20/750, 22/828, 25/881, 26/915).Alerts instantly via Teams or email whenever a circular amends a text you have referenced in your ICT policies.Detects divergences between official language versions, such as the addition of third-country PSP branches in the English version only.Automatically maps your internal policies (ICT risk management, business continuity, incident management) and flags those citing an obsolete version.Generates a timestamped monitoring log, enforceable before the CSSF, demonstrating that your framework tracks the version in force at all times.Produces a before/after comparison view for each amendment, so you can prioritise your update work.Available as a complement to a Luxgap CISO mandate or as a dedicated SaaS module depending on your scope. Request a tailored quote and our teams will prepare a demonstration on your real regulatory corpus, with a free blank audit within 48h to measure your exposure before any engagement.

Entry into force, signatories and annex

They trust us

Before we chat