Reminder: ICT Incident Reporting – Execution Is the Real Challenge
TechnologyThe CSSF has recently reiterated a key message for all supervised entities: if a major ICT-related incident occurs, it must be reported—promptly and without exception.

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The CSSF has recently reiterated a key message for all supervised entities: if a major ICT-related incident occurs, it must be reported—promptly and without exception.
The Commission de Surveillance du Secteur Financier (CSSF) has issued two Circulars — CSSF 25/893 and CSSF 25/892 — that reinforce Luxembourg’s commitment to implementing the Digital Operational Resilience Act (DORA). These circulars provide a comprehensive regulatory framework for ICT-related incident classification and reporting, as well as for estimating the financial impact of such incidents. Branches in Luxembourg of financial entities whose head office is based in another EU Member State (EU branches) are expected to report major ICT-related incidents, significant cyber threats and their estimations to the competent authority of their home Member State under DORA. As such, they are excluded from the scope of these circulars.
The three European Supervisory Authorities (EBA, EIOPA, and ESMA, collectively known as the ESAs) have unveiled the second batch of policy products under the Digital Operational Resilience Act (DORA). This latest release comprises four final draft regulatory technical standards (RTS), one set of Implementing Technical Standards (ITS), and two guidelines, all designed to bolster the digital operational resilience of the European Union’s financial sector.