From a directive to a regulation

On the tenth of July 2027, Regulation 2024/1624 applies, and most of what you do today does not disappear. It gets restated in a European instrument that applies directly, without a Luxembourg law in between. Start with why that matters, because it is not a technicality. A directive tells member states what result to achieve and leaves them to legislate. That is why the framework you work in is Luxembourgish: a law of 2004, a grand ducal regulation, a CSSF regulation. Twenty seven member states each did that, and they did it differently.

A regulation applies as it is written, in every member state, at the same moment. There is no transposition, and no national variation to hide behind. Now the consequence nobody budgets for. Every internal procedure you own cites Luxembourg provisions. Your customer due diligence policy cites article 3.

Your appointment paperwork cites articles 40 to 45 of the CSSF regulation. Your training programme cites article 46. After July 2027, a reader following those citations arrives at provisions that no longer carry the obligation. Nobody is going to do that renumbering for you, and the volume of it is the single most underestimated part of this transition. It is also the part you can start today, which is why it opens this course.

One caution before we go further, and it runs through the whole module. The directive is not gone. Directive 2024/1640 sits alongside the regulation, and it is transposed nationally, on its own timetable. So the answer to, is it all European now, is no. Some of it is directly applicable, some of it arrives through Luxembourg law, and knowing which is which is the same habit this framework has always demanded.