EMIs and PIs - Specificities of the Luxembourg regulatory framework

For existing and future Luxembourg PI and EMI:

• Authorised managers
• Board members
• Persons responsible for the internal control functions

And for investors looking to create an EMI/PI and who want to better understand the activities related to these licences and underlying regulatory obligations.

This course offers a practical and operational introduction to the regulatory environment that applies to Payment Institutions (PI) and Electronic Money Institutions (EMI) operating in Luxembourg. With the publication of CSSF Circular 26/906, the governance and risk management expectations for PIs/EMIs have entered a new phase, marked by heightened supervisory scrutiny, stronger substance requirements and reinforced accountability of the management body.

This training is designed to help newly licensed or incoming market players understand what 'being supervised in Luxembourg' truly means, and how to navigate supervisory expectations from day one.

By the end of this training, participants will be able to:

• understand the core features of the Luxembourg regulatory framework for PIs and EMIs, and how these interact with EU-level requirements;
• Identify the key governance, substance, and risk management expectations introduced by CSSF Circular 26/906;
• clarify the roles and responsibilities of the management body, authorised managers, and internal control functions in the Luxembourg context;
• recognise typical supervisory pain points and areas where institutions often face challenges or misunderstandings;
• assess the implications of proportionality, outsourcing rules, safeguarding obligations and client communication requirements on daily operations;
• build a clear roadmap to ensure readiness for supervisory engagement and ongoing compliance.

• Overview of the Luxembourg regulatory landscape for PIs/EMIs
• CSSF Circular 26/906: a new governance baseline
• Roles and responsibilities of key functions
• Operational and risk management requirements
• Conduct, communication and client protection rules
• Outsourcing and reliance on group/support structures
• Preparing for supervision and market trends

This training is coordinated by Isabelle Melcion-Richard, Partner at PwC Luxembourg.

Isabelle Melcion-Richard is a partner at PwC specializing in regulatory assistance for new applicants to Luxembourg’s regulated financial sector, including credit institutions, Professionals of the Financial Sector (PFS), electronic money, and payment institutions. With over 25 years of experience in Luxembourg’s financial sector, she leads regulatory advice and has developed expertise in designing application files, governance manuals, authorisation requests, and notification documents. Isabelle is actively involved in industry associations such as ALCO and ALJB. Her work includes drafting application and notification files, regulatory analysis, compliance manual development, gap analysis, and supporting on-site inspections and remediation plans.