This presentation was prepared for the ABBL/CSSF workshop held on 24 March 2026 and provides an overview of the new CSSF Circular 26/906 on governance for payment institutions (PIs) and electronic money institutions (EMIs). It outlines key regulatory expectations related to central administration in Luxembourg, internal governance frameworks and risk management requirements. The document covers essential topics such as the roles and responsibilities of management and supervisory bodies, the “three lines of defence” model, safeguarding of client funds, and organisational requirements including conflict of interest management and new product approval processes. It also highlights the importance of proportionality and the need for institutions to implement robust, well-documented governance structures aligned with their business model and risk profile.
