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A register accepted at filing can still be refused later

What the CSSF and the Central Bank of Ireland published about ESA content checks that follow the national collection of registers of information.

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What the sources say

Two national competent authorities described a second step that comes after the national collection.

The Commission de Surveillance du Secteur Financier (CSSF, Luxembourg) wrote in February 2026:

"Registers of information accepted by the CSSF may be submitted on request to the ESA which will perform additional validation checks." (Z-1)

"Should the ESAs detect additional errors and consequently refuse the register of information on their side" (Z-2)

The CSSF wrote in March 2026:

"The ESA will perform additional quality control checks throughout the month of April 2026" (Z-4)

The Central Bank of Ireland (CBI) wrote:

"The EBA announced, in the week commencing 16 Feb 2026, that there will be an additional review step to be performed on the content of the data submitted in the Registers of Information" (Z-5)

"in April 2026, the EBA will run Data Quality (DQ) checks on all Registers" (Z-6)

All of these are announcements in the future tense. The pages above do not report how many registers were refused.

What this means for your register

Acceptance by the national portal and the content review announced by the CSSF and the CBI are two different steps. A file that passes the technical checks at filing can still contain values that a later content review may question, for example placeholder identifiers or generic names. The CSSF page describes the case where the ESAs refuse a register "on their side" after the CSSF accepted it.

How to check before filing

  • Read every row as a person would, not only as a validator would. Ask whether each identifier, name and country points to a real entity.
  • Treat any value you typed only to get past a mandatory field as a finding to fix, not as a finished cell.
  • Keep the feedback files from earlier submissions and compare them with the current register.
  • The other pages in this series cover three examples named by the CBI and the CSSF: placeholder LEIs, "not applicable" values and links between templates.

Sources

This page is general information and is not legal advice.