Innovation Hub

Financial innovation affects all financial sector activities and increasingly reshapes the way these activities are carried out and how the related financial services are used by clients. Integration of evolving technology-based innovation in financial services and markets is a continuing challenge for regulators such as the CSSF, calling:

• on the one hand, for a proactive flexible regulatory approach in order not to hinder new opportunities and benefits by creating excessive regulatory barriers for innovation; and
• on the other hand, for a prudent risk-based regulatory approach in order to safeguard the role of prudential supervision and supervision of the financial markets in ensuring the safety and soundness of the financial sector with a special focus on consumer protection, market confidence and AML issues.

To reach this goal, on a case-by-case basis, the CSSF combines a technology neutral approach where the legal qualification of each project presented to the CSSF is assessed on the basis of the services effectively provided regardless of the technology used, with a risk-based approach.

In line with this risk-based approach, the CSSF has published a certain number of documents to inform the public on its positions on subjects related to the financial innovation as listed below, as well as in the sections dedicated to specific business models and innovative technologies found at the bottom of this page.

List of MoUs signed in the field of innovation in financial services.

1. Preparation of the first contact

Determine the type of interaction I want to have with the Innovation Hub:

• Ask a question: “I have a specific question with regard to my project or its applicable regulatory framework”;
• Present a project for information only. Projects that usually fall into this category are, for example, innovative business models at an early stage of development that may touch the financial sector whether they need a specific authorisation/registration or not or RegTech solutions;
• Present a concrete project: “I want to present a project with a concrete business case, which is at an advanced stage of development, for which a preliminary analysis was performed in terms of its applicable regulatory framework and with the objective to request a preliminary assessment and later apply for an authorisation/registration or to formally notify the CSSF of my intended activities”.

Read carefully the General Guidance located on the last page of the Contact Form.

Prepare the necessary information and documentation.

• The Contact Form duly completed. Please complete all relevant parts of the form that provide the details needed to fully understand your question(s) or project.
• If necessary, please provide any additional documentation (e.g. legal memorandum, PowerPoint presentation…).

2. Contact with the Innovation Hub

Contact the Innovation Hub via email at innovation@cssf.lu and attach the relevant information to the email (i.e. the Contact Form and any additional information as mentioned above).

Once the Innovation Hub has received your email, it may respond directly to your question(s) or request additional clarification or missing information to provide answers to your question(s) or better understand your project.

3. Meetings and/or exchanges

Regarding projects that require regulatory guidance in view of potential licensing requirements and depending on the progress of your project, the Innovation Hub may organise a meeting to which it will invite, if necessary, the relevant specialists from different departments.

In order to optimally prepare for the meeting and to facilitate the exchanges as well as to allow you to illustrate your business model, it is good practice to send us presentation slides and to ask any preliminary questions related to your project at least a week in advance.

4. Follow-up

The next steps depend on the action items identified during the email exchanges or during the meeting with the CSSF.

As a general rule, the Innovation Hub is interested in being informed of future significant developments affecting projects which could have consequences from a regulatory standpoint.