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A register accepted last year can be rejected this year

The CSSF warned that a register of information accepted last year may be rejected this year. What that means when you reuse last year's file.

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What the sources say

The Commission de Surveillance du Secteur Financier (CSSF, Luxembourg) wrote in its February 2026 notice on the submission timeframe that the checks themselves have not changed:

"The validation checks defined by the ESA and last updated in April 2025 have not changed" (Z-22)

The same paragraph announces that these checks will cover more data fields:

"will be applied to more data fields in order to increase the quality of the received data" (Z-23)

From this, the notice draws its conclusion:

"a register of information which was accepted last year, may be rejected this year" (Z-3)

The same notice describes the additional step after national acceptance:

"Registers of information accepted by the CSSF may be submitted on request to the ESA which will perform additional validation checks." (Z-1)

What this means for your register

The CSSF statement is about one authority and one notice. According to that notice, the reason is not a change in the checks. The checks defined by the ESA have not changed, and the CSSF announced that they will be applied to more data fields. That is why, in certain cases, an earlier acceptance does not protect the next submission. A register that is copied from last year and updated only where something changed may hold values in data fields that the checks did not cover last year and will cover this year. The paragraph quoted above does not name the additional data fields.

How to check before filing

  • Do not treat last year's acceptance message as proof that the content is fine this year.
  • Compare this year's register with last year's file and list what changed: new providers, ended arrangements, new functions, changed identifiers.
  • Re-read the rows that did not change. Old placeholder values can survive unnoticed in rows nobody edited.
  • Keep last year's feedback files and check whether any finding marked as a warning then is still present.

Sources

This page is general information and is not legal advice.