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This Circular applies to all financial entities covered under DORA, as well as Payment Service Providers (PSPs) not directly within DORA’s scope — including POST Luxembourg and third-country branches operating in Luxembourg. These entities are now required to comply with DORA reporting obligations, streamlining the regulatory framework and avoiding fragmented reporting channels.
Payment Service Providers (PSPs) not under DORA must classify ICT-related incidents and cyber threats using the criteria and thresholds in Chapters I–III of the RTS on classification. They are also required to fully comply with the RTS and ITS on incident reporting for notifying major ICT-related incidents and significant cyber threats. Chapters IV and V of the RTS on classification do not apply to them.
Key Requirements
For Payment Service Providers (PSPs), this circular will take effect six months after its publication. During the transition period, they must continue to follow the classification criteria and reporting procedures outlined in Circular CSSF 24/847 and Circular CSSF 21/787, which implement the EBA Guidelines (EBA/GL/2021/03) on major incident reporting under PSD2.
For all other financial entities, this circular takes immediate effect and supersedes Circular CSSF 24/847 on the ICT-related incident reporting framework. Additionally, Circular CSSF 21/787, which implemented the EBA Guidelines (EBA/GL/2021/03) on major incident reporting under PSD2, is no longer applicable to them.
Furthermore, six months after the publication date of this circular, Circular CSSF 21/787 on application of the EBA Guidelines (EBA/GL/2021/03) on major incident reporting under PSD2 will be repealed.
In line with Article 11(11) of DORA, this Circular adopts the Joint Guidelines (JC 2024 34) developed by the European Supervisory Authorities (ESAs) — EBA, EIOPA, and ESMA. These guidelines are designed to standardize how financial institutions estimate and report the financial impact of major ICT-related incidents. Microenterprises are not in scope of this Circular.
Upon request by the CSSF, financial entities must provide:
Entities may choose between calendar year, or accounting year (as defined in their financial statements). However, once a method is selected, it must be used consistently in future reports.
Estimation Approach:
This circular will be applicable starting from 31 May 2025.
What should you do next?
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In any case of questions, please contact our Chief Information Security Officer Sabika Ishaq, or our Senior Information Security Manager, Magdalena Mihalcea.
Are you ready to take control of your compliance process like never before? Look no further than our cutting-edge DORA tool - the ultimate solution designed to empower you every step of the way.