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New annual reporting framework for support PSF

13 February 2024

Regulatory News Alert

At a glance

On 19 January 2024, CSSF published the CSSF circular 24/850 defining the practical rules for the new regulatory requirements for Support PSF and their Réviseurs d'Entreprises Agréés (REA) for closings on 31 December 2023. These submissions must be made by Support PSF via the CSSF e-desk platform within 7 months after closing.

A closer look

The new circular 24/850 is repealing the CSSF circular 12/544 and 19/727, replacing the risk assessment report (RAR) by the self-assessment questionnaire (SAQ) and simplifying the descriptive report (DR) to be provided on an annual basis by Support PSF.

Under the new circular, the Réviseur d’Entreprises Agréés (REA) will prepare:

  • A separate report according to a model provided by the CSSF for each year/period, and based on the self-assessment questionnaire (SAQ) submitted by the support PSF.
  • A management letter, which will be limited to statutory audit.

The above-mentioned requirements and regulatory framework are applicable for the first time for financial years closing on 31 December 2023, or after 31 December 2023.

Below is a list of reporting templates for the specific reporting of the REA:

Reporting templates for the specific reporting of the REA

Management letter

Weaknesses and points needing improvements and follow-up points of the preceding financial years

Rotation plan
for the separate report


Rotation plan established by CSSF based on risks

Art. 29-1 and 29-2 LFS

Low / Medium / High risk

Art. 29-3, 29-5 and 29-6 LFS

Low risk

Art. 29-3, 29-5 and 29-6 LFS

Medium risk


Art. 29-3, 29-5 and 29-6 LFS

High risk

How can Deloitte help?

Practically speaking, accurately completing a support PSF’s SAQ has proven to be quite difficult, generating a workload that requires highly technical skills, which can quickly become time consuming and drain resources.

Deloitte can support you in your readiness for this new reporting scheme:

  • Support in amending the descriptive report
    We will support you in reviewing the previous year's descriptive report and propose changes that comply with the new requirements.
  • Assistance in data gathering and SAQ preparation
    We will support you in understanding the SAQ questions, identifying the accurate set of information to collect, clarifying the scope of services/systems addressed by each question, and draft a first version of the answer.
  • Readiness assessment for REA procedures in the separate report
    We will help you prepare for the procedures performed by your REA within the context of the separate report. We can perform a rehearsal set of procedures and propose improvements either in the documentation provided to the REA or in the internal processes covered by the REA’s procedures.

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