CSSF Supervisory Priorities 2026

Preparing for a more intrusive supervisory environment

The CSSF’s communications of 2 March and 31 March 2026 point towards a significant change in supervisory practice. The focus is moving from policies and procedures towards implementation, oversight and evidence.

For IFMs, boards and conducting officers, the question is no longer whether a framework exists. The question is whether the organisation can demonstrate that governance, delegation oversight, sustainability risk integration and operational controls work in practice.

Origo Consulting can help you get ready for inspections.

Self-assessment

Most firms discover weaknesses when a supervisor identifies them. A better approach is to identify them beforehand.

Origo Consulting has developed an Inspection Readiness Questionnaire for Luxembourg IFMs. It provides a structured review of areas currently receiving increased supervisory attention. The questionnaire is available free of charge.

Independent review

Completing a questionnaire is one thing. Determining what the answers mean is another.

Origo Consulting can review the completed questionnaire and prepare a concise board-level report. The report identifies areas that may deserve attention before they attract supervisory attention. The objective is to help boards and management focus their attention where it matters most.

Deep-Dive reviews

Some issues require a closer look.

Where a review identifies areas of concern, targeted DeepDive reviews can be performed. These reviews focus on specific topics such as governance, delegation oversight, sustainability risk integration and operational controls. The purpose is to move from broad observations to a detailed understanding of the issues involved.

Learn more about Origo’s Review Process