Transparency goes digital: the CSSF launches eRIIS

In the continuous strive to become more user friendly and facilitating communication, the CSSF has launched the electronic Reporting of Information concerning Issuers of Securities (eRIIS). This new web application is available on the CSSF’s website for issuers or other persons subject to the Law of 11 January 2008 on transparency requirements for issuers (the Transparency Law) and the Regulation (EU) No 596/2014 (Market Abuse Regulation). These persons will be able to fulfil their filing obligations through eRIIS as well as use it as a channel of communication with the regulator.

In order to be able to use the system, entities should check if an account needs to be created. For issuers subject to the Transparency Law, a Reporting Entity will exist in eRIIS as from the moment they fall within the scope of the Transparency Law. The information to be submitted includes ongoing information under the Transparency Law, such as notifications of major holdings as well as the various reports to be submitted as part of the periodic information requirements. Issuers will also be required to submit their choice of Home Member State as required by the Transparency Law on the platform. With respect to the market abuse obligations, this will include the inside Information and manager’s transactions notification.

Although the deadline for using the platform is the end of May 2022, the CSSF has encouraged all concerned persons to use eRIIS as soon as possible. A LuxTrust certificate is required to access the eRIIS platform.

In connection with the launching of the platform, the CSSF has also published Circulars 22/799 and 22/800 in order to reflect the changes that have taken place in relation to the introduction of the CSSF’s application eRIIS. The CSSF also has a number of documents on its website containing information of a technical nature (eRIIS – CSSF).

This development matches the CSSF’s drive to modernise and embrace technology. Whilst the information to be provided and the legal obligations remain unchanged, the process should become easier and more manageable for entities concerned. The dedicated platform will not only allow for communication with the competent team within the CSSF but will also allow follow-up on regulatory filings, notably by consulting various dashboards and tracking the status of individual filings.

The platform also introduces the ability for reporting entities to delegate administrative related tasks to third parties and defining various access rights, whilst remaining able to manage the reporting obligations. The obligation to ensure the reporting is done correctly remains with the reporting entity, despite any delegation.

If you have any questions regarding the Transparency Law or the requirements relating to Market Abuse, please contact Cathrine Foldberg Møller or Louis-Maël Cogis.