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New CSSF circular on outsourcing arrangements – what will change for you

On 22 April 2022, the CSSF published CSSF circular 22/806 on outsourcing arrangements. The CSSF provided useful guidance on the implementation of the new CSSF circular in a dedicated FAQ.

It also clarified in a separate CSSF circular 22/805 how existing CSSF circulars dealing with outsourcing requirements will be amended or repealed. In-scope entities of CSSF circular 22/806 must ensure that outsourcing arrangements entered into, reviewed or amended on or after 30 June 2022 are compliant with the new requirements. In respect of existing outsourcing arrangements, in-scope entities shall adjust the relevant documentation the earliest of either the first renewal date of the arrangement or 31 December 2022[1].

[1] This eAlert discusses the key points of the new CSSF circular. It should not purport to be an exhaustive analysis of, or contain definitive advice on the changes brought by the CSSF circular 22/806.