Luxembourg Reporting Obligations
Understanding the Transition from Authorised Channels to the CSSF’s S3 API model
The landscape of report submissions in Luxembourg is undergoing a digital transformation. As the Commission de Surveillance du Secteur Financier (CSSF) moves towards a self-serve method of reporting, many entities are seeking clarity on how these changes will affect them. With the transition from authorised channels like e-file to the CSSF’s eDesk portal and the introduction of the S3 API, several questions have arisen regarding the practical implications and necessary steps involved.
In this article, we address the most frequently asked questions surrounding this transition. From understanding the reasons behind the shift to navigating the new submission processes, our Q&A provides comprehensive insights to help you remain compliant and efficient in your reporting duties. Whether you are concerned about the role of e-file, the specifics of the S3 API or the differences between e-file and the CSSF’s eDesk, this guide is designed to provide you with the essential information you need.
Read on to familiarise yourself with the key changes and ensure a smooth transition in your reporting practices.
Key Q&A Points
1. Why are Luxembourg report submissions transitioning from authorised channels such as e-file to the CSSF’s eDesk?
In 2023, the Commission de Surveillance du Secteur Financier commenced a process aiming at making reporting transmission more digitised and direct. Through their version of an open architecture model, called S3 API, paired with the eDesk portal, the CSSF transitioned from allowing report submission via two authorised channels (one of them being Fundsquare’s e-file) to a self-serve model. As a result, the previously authorised transmission channels are still in operation, although under a different label of a ‘third party supplier’.
2. Which reports are affected by this transition?
The CSSF hasn’t disclosed the full list of reports that will be affected. The CSSF currently makes announcements ahead of each report to be transitioned. So far, AiFMD Annex IV, UCITS Marketing Notification, Corep-Finrep ALM and LCRDA reports have been transitioned with Key Information Documents (KID) and Management Regulations or Articles of Incorporation documents (MR/AI) and U1.1 reporting transition underway, and MiFIR/TAF potentially in the pipeline for next year.
3. What happens to e-file as a result?
The role of e-file doesn’t change. E-file remains the market leading platform for comprehensive report submissions. E-file also remains compatible with S3. Following the acquisition of Fundsquare by FE fundinfo in 2022, the breadth of services provided by e-file has evolved with further investment and development in scope. E-file features functionality essential to fulfill an asset manager’s reporting obligations accurately and efficiently, some of which the self-serve solution doesn’t cover and offers easy access to our specialist support team. Furthermore, FE fundinfo’s broader capabilities facilitate the end-to-end cross-border report production and distribution requirements.
4. What is the CSSF’s S3 API?
It is a new transmission model that replaced the Luxtrust SSL certificate and keystore system.
5. What do I need to do to remain with e-file?
As soon as we become aware of a report being transitioned to S3, we contact our clients of the report with guidance on what steps to take to ensure you can continue to transmit your reports via e-file. We also recorded a video that takes you through this process step by step.
6. How did the submission process change on e-file since the CSSF’s transition to S3?
From a user’s perspective, the filing process remains the same after importing S3 keys (via the e-file portal or the Sending Service). It is a purely technical change, for example, as if you changed the engine of a car from a combustion engine to an electric motor – while the engine has changed, the rest of the car remains the same (screens, dashboard etc).
7. What action needs to be taken to remain with e-file?
We ask our clients to perform ‘S3 keys import into e-file’. In practice, this means that you’ll need to simply generate the S3 key via the IT expert profile on eDesk and import it into e-file.
8. What are IT expert and Advanced user profiles on eDesk?
These profiles give users certain permissions, with the IT expert providing a generic set of permissions and Advanced user providing a similar set of permissions to an e-file’s Administrator profile. E-file can be connected to eDesk and S3 at IT expert level. By transferring to our IT expert S3 keys, you will enable e-file to act as your profile with transmission permissions and perform all the same e-file functions as prior to transition to S3.
9. What are the differences between FE fundinfo’s e-file and the CSSF’s eDesk?
In short, S3 is the transmission channel, e-file is a reporting platform. To try and explain the purpose and capabilities of both, we use a simple parallel, where S3 can be compared to a rail track and e-file to a train station with several rail tracks and journey options available. They are simply different models of report submission, with eDesk being a self-serve model limited to its sole purpose of report transmission to the CSSF and, naturally, without some of the functionality that e-file has being a multi-report, cross-border reporting platform.
10. What are the unique features of FE fundinfo’s e-file?
We categorise e-files features into compliance oversight and user functionality. Compliance oversight includes a dashboard that offers progress tracking of all transmitted and submission-pending documents across domiciles, across providers (such as fund administrators, if present), as well as submission confirmation information (date, time, feedback from regulator). A user can simply press a button to determine which documents, for which jurisdictions, are pending action or submission to the regulator. User functionality includes features that make your life much easier, such as archive functionality for all submissions for up to 10 years, and pre-defined, compliant and up to date document templates, along with permission controls down to the per-template level.
11. Will my existing e-file credentials work on CSSF’s eDesk?
They won’t, as eDesk is a different platform to e-file, managed by the CSSF. To continue using e-file for your reporting transmission, you will need to take certain steps, including linking S3 keys to e-file, as outlined in the following video.
12. What should I do if I encounter issues during the transition?
Our Support Team is available to answer any of your questions and provide step-by-step instructions. Contact details for our multilingual support team are listed under question 16.
13. Are there any training resources available on how to ensure my reporting remains with e-file?
Yes, we outlined necessary steps to follow in this video.
14. Can I still access historical reports on e-file?
Yes, historical reports submitted through e-file will remain accessible.
15. Will there be any changes to the reporting deadlines?
No, the reporting deadlines will remain unchanged. The transition solely pertains to the platform used for report submission.
16. Who can I contact for further questions?
If you have any questions regarding this transformation, e-file or FE fundinfo products in general, we are available to answer them for you.
We appreciate your understanding and cooperation during this transition period. Should you have any further enquiries or require assistance, please do not hesitate to reach out to our support lines or contact us using the details below. Our team is dedicated to ensuring a smooth and efficient process for all users.
Contact us: [email protected]
English support line: +44 19 0421 14 02
French support line: +352 27 863 969
German support line: +41 4350 874 94