Timeline & deadlines: When and how to submit your CSSF SFDR JSON reports
Meeting the Commission de Surveillance du Secteur Financier's (CSSF) requirements for sustainable finance disclosures is essential for Luxembourg-domiciled funds. This blog navigates the timeline and deadlines for submitting your SFDR disclosures in both PDF and JSON formats, providing a step-by-step guide to ensure timely and compliant filings that meet regulatory and investor expectations.
As part of its sustainable finance obligations, the Commission de Surveillance du Secteur Financier (CSSF) now requires Luxembourg-domiciled funds to submit pre-contractual and periodic SFDR disclosures in both PDF and JSON format. Understanding when and how to meet these requirements is critical to avoid late filings, regulatory breaches, or investor confusion.
In this article, we clarify the regulatory calendar for CSSF SFDR submissions and walk you through the filing process — from preparation to eDesk upload.
SFDR Reporting: Two key disclosure types
Both must be filed in:
• PDF format for investor transparency
• JSON format for regulatory validation via CSSF
Key CSSF deadlines (2025 reporting cycle)
Periodic Reporting (Annex V JSON)
For most Luxembourg UCITS and AIFs, the first periodic SFDR JSON submission covers reporting year 2024, due in Q1/Q2 of 2025, depending on the fund’s financial year-end.
From 2024 onward, disclosures must be submitted within one month after the legal annual report deadline, and no later than 5 months after year-end for UCITS or 7 months for AIFs and IORPs.
Reminder: The JSON should be accompanied by the PDF if: It is a Periodic, LU non-regulated fund or if it is a Pre-Contractual report and a PDF has never been submitted prior.
Pre-contractual Reporting (Annex II & III JSON)
Annex II & III disclosures must be updated and submitted:
- At product inception
- Whenever there is a change to the original fund strategy
- As part of periodic updates to prospectus/issuing documents
There is no fixed calendar date, but CSSF requires:
• Timely update of eDesk records
• Submission of JSON file before/with legal updates
How to submit your SFDR JSON File to the CSSF
- Prepare your files
You must prepare:
- PDF version of Annex II, III, IV or V
- JSON file aligned to the CSSF schema
- Ensure both files match in data and structure
2. Validate your JSON
Use tools or services that support:
- CSSF schema validation
- Logical consistency checks (e.g., asset allocation totals)
- UTF-8 encoding
3. Submit via CSSF eDesk portal
Navigate to the SFDR Reporting Module in CSSF eDesk:
- Select the fund and reporting period
- Upload the Annex
Files that fail validation will not be accepted.
Each of these steps can be done within the FE Fundinfo product Eco-System between Nexus and E-File.
Example regulatory calendar: SFDR submission planning
Tips to stay ahead of deadlines
- Create an SFDR reporting calendar aligned with your fund year-ends
- Maintain a single ESG data repository for consistency
- Use automated reminders for validation and submission checks
- Monitor CSSF circulars and updates on JSON schema changes
- Designate a submission owner per fund to ensure accountability
Conclusion: Don’t let deadlines derail compliance
The CSSF’s digital-first approach to SFDR is a shift toward regulatory precision and automation. With clear submission windows, dual-format filing, and technical validation, firms must embrace structured reporting and keep a close eye on timing. A missed SFDR deadline is not just a procedural issue — it may signal governance risk to both regulators and investors.