{"id":"circulars/faq-faq-national-reporting-b4-5-and-b4-6","title":"FAQ national reporting B4.5 and B4.6","type":"circular","date":"2024-01-15","kind":"faq","html":"<p>FAQ national reporting B4.5 and B4.6 is a CSSF FAQ, published 15 January 2024.</p>\n<p>Relevant for: Credit institutions.</p>\n<p>Keywords: eDesk.</p>\n<h2>Text</h2>\n<p>FAQ National reporting B4.5 and B4.6 23/04/2025</p>\n<p>FAQ NATIONAL REPORTING B4.5 AND B4.6 23/04/2025</p>\n<p>FAQ National reporting B4.5 and B4.6 23/04/2025 12/01/2024</p>\n<p>Initial version</p>\n<p>30/12/2024</p>\n<p>Update of Q4 and Q8. Publication of Q11 Update of Q10 (new example on how to report the shareholding structure) and</p>\n<p>23/04/2025</p>\n<p>Q11</p>\n<p>TABLE OF CONTENTS Context Useful links CSSF FAQs Q1 Is it possible to send the reports in OTHREP format via historical channels SOFiE/E-file or MFT? Published on 12/01/2024 Q2 What is the reporting frequency? Published on 12/01/2024 Q3 As a branch of an EU credit institution we have never submitted a B4.5 report. Now that both reports are merged into one procedure, should we report the data? Published on 12/01/2024 Q4 What is the reference period for the reporting? Published on 12/01/2024 Modified on 30/12/2024 Q5 How should the new fields “starting date” and “ending date” be filled in? Published on 12/01/2024 Q6 How should a function which is not currently occupied be reported? Published on 12/01/2024 Q7 Is it possible to correct errors once the report has been submitted? Published on 12/01/2024 Q8 How to report changes occurring during the year? Published on 12/01/2024 Modified on 30/12/2024 Q9 How to report if there are no changes compared to the previous submission?</p>\n<p>FAQ NATIONAL REPORTING B4.5 AND B4.6 23/04/2025</p>\n<p>Published on 12/01/2024 Q10 What is the correct sequence numbering for B4.5 Analysis of shareholding? Published on 12/01/2024 Modified on 23/04/2025 Q11 Should the complete list of shareholders be reported, even those that are not qualified? Published on 30/12/2024 Modified on 23/04/2025 Annex: list of requested functions and activities for B4.6</p>\n<p>FAQ NATIONAL REPORTING B4.5 AND B4.6 23/04/2025</p>\n<p>Context From 2 January 2024, the CSSF requires that credit institutions transmit their national reports B4.5 (Analysis of shareholdings) and B4.6 (Persons responsible for certain functions and activities) using one of the two following methods: •</p>\n<p>A dedicated eDesk approach accessible via the eDesk Portal;</p>\n<p>An API solution based on the submission of a structured exchange file (json format) via the S3 protocol (“simple storage service”).</p>\n<p>Historical national reportings “B4.5 - Analysis of shareholdings” (Circular CSSF 12/553) and “B4.6 Persons responsible of certain functions and activities” (Circular CSSF 13/576) are merged into a single eDesk procedure National Banking Reporting. Following the dedicated communication and the start of the reporting campaign, the CSSF has received several questions from supervised entities (SEs). As some of the questions may be of interest for other SEs as well, the CSSF has decided to make these questions and answers public. These FAQs aim at clarifying certain elements of the new procedure. The FAQs will be regularly updated when required. Please note that the list of requested functions and activities for section B4.6 is available in the annex of the FAQ. The corresponding user guide is also available on eDesk, detailing the procedures for completing, validating and submitting these B4.5 and B4.6 national reports.</p>\n<p>Useful links Circular 12/552 on Central administration, internal governance and risk management as amended <a href=\"https://www.cssf.lu/wp-content/uploads/cssf12_552eng.pdf\" target=\"_blank\" rel=\"noreferrer\">https://www.cssf.lu/wp-content/uploads/cssf12_552eng.pdf</a> Circular 12/553 Update of table B 4.5 as amended <a href=\"https://www.cssf.lu/wp-content/uploads/cssf12_553eng.pdf\" target=\"_blank\" rel=\"noreferrer\">https://www.cssf.lu/wp-content/uploads/cssf12_553eng.pdf</a> Circular 13/576 Update of table B 4.6 <a href=\"https://www.cssf.lu/wp-content/uploads/cssf13_576eng.pdf\" target=\"_blank\" rel=\"noreferrer\">https://www.cssf.lu/wp-content/uploads/cssf13_576eng.pdf</a> Circular 14/593 on Supervisory reporting requirements applicable to credit institutions as amended <a href=\"https://www.cssf.lu/wp-content/uploads/cssf14_593eng.pdf\" target=\"_blank\" rel=\"noreferrer\">https://www.cssf.lu/wp-content/uploads/cssf14_593eng.pdf</a> Reporting requirements for credit institutions handbook</p>\n<p>FAQ NATIONAL REPORTING B4.5 AND B4.6 23/04/2025</p>\n<p>CSSF FAQs Q1 Is it possible to send the reports in OTHREP format via historical channels SOFiE/E-file or MFT? Published on 12/01/2024 No.</p>\n<p>The text above is the opening of the document; the PDF carries the whole.</p>\n<p><a href=\"https://www.cssf.lu/en/Document/faq-national-reporting-b4-5-and-b4-6/\" target=\"_blank\" rel=\"noreferrer\">Document page</a>, <a href=\"https://www.cssf.lu/wp-content/uploads/FAQ-national-reporting-B4.5-and-B4.6.pdf\" target=\"_blank\" rel=\"noreferrer\">PDF</a>. Source: Commission de Surveillance du Secteur Financier (CSSF), reproduced with the CSSF's consent. The French text prevails.</p>"}