Law, Tax, Compliance
CSSF Circular 26/906: a key milestone for PI and EMI governance
Published on 20 January 2026
The CSSF has published Circular CSSF 26/906, introducing a consolidated framework on central administration, internal governance and risk management applicable to payment institutions (PI) and electronic money institutions (EMI). This publication comes at a key moment for the sector, which continues to grow rapidly in terms of transaction volumes and operational complexity, and calls for robust and clear governance arrangements.
Summary
Key takeaways
- Formalised and documented proportionality assessment
- Enhanced governance architecture for the Board and the Management
- Reinforced internal control functions framework and additional duties in their roles
- Stronger framework for fit and proper assessment and conflicts of interest
ABBL advocacy
The ABBL has advocated for a framework that remains fully aligned with the PSD2 Directive and with national transposition legislation, and that avoids additional obligations not grounded in EU or national law.
The ABBL has also called for a framework adapted to the operational realities of PIs and EMIs.
The institutions concerned have work to complete by 30 June 2026. The ABBL is ready to support this work within the relevant ABBL working groups.
Further information
Galina Miroshnichenko
Adviser – Payments & Digital, ABBL
Published on 20 January 2026