CSSF moves prudential reporting to eDesk from April 2027

The CSSF will make eDesk the sole official channel for prudential reports from payment institutions, electronic money institutions and Article 63 MiCAR crypto-asset service providers from 1 April 2027.

In a notice published on 10 September, the CSSF set out the migration from the current Excel-based process. The notice concerns CASPs authorised under Article 63 of MiCAR, alongside PIs and EMIs.

The CSSF will publish a dedicated circular replacing Circulars CSSF 11/511 and 11/522. The circular will introduce specific reporting obligations for Article 63 CASPs, but the notice does not provide it.

The reporting structure will use dynamic forms tailored to each entity’s licence and characteristics, including whether an EMI issues e-money tokens and whether an entity has foreign branches. Annex 1 lists the data points and preparatory guidance, although the CSSF said labels and guidance may undergo minor changes.

Testing runs before the filing channel changes

The new eDesk module will be available for testing from 1 January to 31 March 2027. Submissions made during that period will be test submissions and will not constitute official regulatory filings.

Until 31 March, firms must continue using the current channel for reports due on or before that date, regardless of parallel testing. From 1 April, eDesk becomes the sole official channel for the reports concerned and the previous process will be discontinued.

The transition turns on the filing deadline rather than the reporting period. Reports due from 1 April must use eDesk even where the underlying period ends earlier. The CSSF gives monthly reports for March 2027 due in April and first-quarter 2027 reports as examples.

The new framework provides for quarterly financial and human-resources reporting, including resources allocated to control functions; monthly reporting limited to funds segregation; and an annual section covering shareholding structure, branches, agents and distributors.

The interface will include automated formulas, data carry-overs and integrity controls. Firms may complete and submit forms manually through eDesk or use an S3 connection with a JSON file containing the Annex 1 data. Qualitative comments and follow-up communications will also move into the platform.

For reporting teams, the immediate task is preparation for testing while maintaining the existing filing process. Firms will need to map their licence profile, branches and reporting data to the relevant dynamic sections, then assess whether manual submission or the optional API route is appropriate.

The notice concerns the CSSF’s reporting system and prudential data requirements. It does not itself alter MiCAR’s Level 1 framework or establish an EU-wide reporting channel. Any separate national transposition or supervisory-policy development sits outside this system migration.

The outstanding implementation items are the dedicated CSSF circular, final technical labels and guidance, and the operational eDesk module. The CSSF has not identified a further publication date for those materials.

From 1 April 2027, covered reports must be submitted through eDesk. The next identified implementation event is the testing phase beginning on 1 January 2027; the CSSF circular and final technical materials remain pending.