L3A/LPEA OUTSOURCING GUIDELINES BASED ON CSSF CIRCULAR 22/806

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This white paper, developed jointly by the L3A Operations Committee and the LPEA Central Administration Committee, provides practical, market‑aligned guidance on implementing the outsourcing requirements set out in CSSF Circular 22/806 (as amended by Circular 25/883). It is designed as a hands‑on reference for fund and corporate administrators, compliance teams, and operational leaders navigating the full lifecycle of outsourcing arrangements in Luxembourg.

The paper translates regulatory expectations into actionable steps covering outsourcing inventories, due diligence, risk assessments, contractual standards, monitoring frameworks, intragroup arrangements, exit strategies, and governance structures. It also highlights common industry challenges and offers pragmatic solutions to strengthen operational resilience and regulatory compliance.

Reflecting the combined expertise of L3A and LPEA members, the document aims to support consistent market practice while acknowledging the diversity of operating models across the industry. It is non‑binding and intended to complement — not replace — the formal requirements of the CSSF and the European Supervisory Authorities.

Document published in February 2026.

Drafted by the L3A contributors: Hakim Torchi, Sambhav Chandhok, Johanna Verazzi, Antonio Frias

Mentored by : L3A Operations Committee Co-chairs - Samuel Kuborn & Alexander Hector