Recital 70
Digital Operational Resilience Act · UE 2022/2554
| (70) | The definition of ‘critical or important function’ provided for in this Regulation encompasses the ‘critical functions’ as defined in Article 2(1), point (35), of Directive 2014/59/EU of the European Parliament and of the Council (20). Accordingly, functions deemed to be critical pursuant to Directive 2014/59/EU are included in the definition of critical functions within the meaning of this Regulation. |
In Luxembourg, the CSSF is both the DORA competent authority and the national resolution authority under BRRD (transposed by the law of 18 December 2015 on resolution, reorganisation and winding-up measures for credit institutions). This duality means the same supervisory team cross-checks both registers during inspections: a divergence between your recovery plan and your DORA register is detected immediately, unlike jurisdictions where both regimes are supervised separately.
Luxgap practice: systematically submit to the CSSF the BRRD-DORA correspondence matrix as an annex to your Article 28 register, even if not formally required. This demonstrates the maturity of your framework and shortens follow-up questions from the on-site inspection unit.
