FAQ Cloud Computing Circular is a CSSF FAQ, published 4 March 2026. It was repealed by Circular CSSF 22/805.
\nRelevant for: AIFMs, AISPs, Credit institutions, E-money institutions, Investment firms, Investment fund managers, Management companies - Chapter 15, Management companies - Chapter 16, Payment institutions, Payment institutions/electronic money institutions/AISPs, Specialised PFS, Support PFS.
\nKeywords: Cloud, Information and communications technology (ICT).
\nCIRCULAR CSSF 17/654 as amended by Circulars CSSF 19/714, CSSF 21/777 and CSSF 21/785
\nIn case of discrepancies between the French and the English text, the French text shall prevail.
\nCircular CSSF 17/654 as amended by Circulars CSSF 19/714, CSSF 21/777 and CSSF 21/785 Re: IT outsourcing relying on a cloud computing infrastructure Luxembourg, 17 May 2017
\nLadies and Gentlemen, To all credit institutions and PFS within the meaning of the Law of 5 April 1993 on the financial sector (LFS) To
\nall
\npayment
\ninstitutions
\nand
\nelectronic money institutions within the
\nthe
\nLaw
\n10 November 2009
\nmeaning
\npayment
\nThe purpose of this circular is to clarify the regulatory framework governing IT outsourcing relying on a cloud computing infrastructure (hereafter also “cloud computing solution”) provided by an external provider. The use of a private cloud without outsourcing is thus excluded from the scope of this circular.
\nservices (LPS)
\nThis circular applies to:
\nTo all investment fund managers
\nsubject to Circular CSSF 18/698 To
\nalternative
\ninvestment
\n1993 on the financial sector (LFS);
\nfund
\nmanagers (AIFMs) and depositaries of
\nalternative
\ninvestment
\nundertaking
\nfor
\ncollective
\ninvestment in transferable securities
\nto all investment fund managers subject to Circular CSSF 18/698;
\nto alternative investment fund managers (AIFMs) within the meaning of
\n(UCITS), to management companies
\npoint (b) of Article 4(1) of the AIFMD and to depositaries of alternative
\nand depositaries of UCITS, as well as
\ninvestment funds (AIFs) referred to in Article 21(3) of the AIFMD;
\nto investment companies that have not
\ndesignated
\nmanagement
\ncompany authorised in accordance
\nto all payment institutions and electronic money institutions within the meaning of the Law of 10 November 2009 on payment services (LPS);
\nfunds
\n(AIFs) To
\nto all credit institutions and PFS within the meaning of the Law of 5 April
\nto undertakings for collective investment in transferable securities (UCITS),
\nwith the UCITS Directive
\nto management companies of UCITS within the meaning of point (b) of
\nTo central counterparties, including
\nArticle 2(1) of the UCITS Directive and to depositaries of UCITS within the
\nTier
\nmeaning of point (a) of Article 2(1) of the UCITS Directive, as well as to
\nthird-country
\ncentral
\ncounterparties, complying with the
\ninvestment companies that have not designated a management company
\nrelevant requirements of EMIR To data reporting services providers and to market operators operating a trading venue
\nauthorised in accordance with the UCITS Directive; f.
\nto central counterparties (CCPs) within the meaning of Article 2(1) of 3
\nEMIR , including Tier 2 third-country CCPs within the meaning of Article
\nTo central securities depositories To
\nadministrators
\ncritical
\nbenchmarks 1 Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010. 2 Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities (UCITS). 3
\nRegulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central counterparties and trade repositories.
\nCIRCULAR CSSF 17/654 as amended by Circulars CSSF 19/714, CSSF 21/777 and CSSF 21/785
\n25(2a) of EMIR, complying with the relevant requirements of EMIR in accordance with point (a) of Article 25(2b) of EMIR; g.
\nThe text above is the opening of the document; the PDF carries the whole.
\nDocument page, PDF. Source: Commission de Surveillance du Secteur Financier (CSSF), reproduced with the CSSF's consent. The French text prevails.
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