Finance & Technology Luxembourg presents industry-led Due Diligence Charter to streamline ICT due diligence
At its 2026 Annual Conference, Finance & Technology Luxembourg (FTL) presented a new Due Diligence Charter and common due diligence package designed to make interactions between financial institutions and ICT service providers more proportionate, efficient, transparent and reusable, without reducing scrutiny or transferring regulatory responsibility. The initiative was unveiled alongside its first 19 official signatories, reflecting early industry engagement around a more collaborative approach to ICT third-party due diligence.
Luxembourg, 11 November 2026 – Finance & Technology Luxembourg (FTL) presented its new Due Diligence Charter and supporting due diligence package at its Annual Conference on 10 November 2026, hosted and sponsored by Intesa Sanpaolo Servitia in Luxembourg. Bringing together some 200 participants under the theme “From Compliance to Collaboration: Building a Trusted ICT Ecosystem”, the conference examined how financial institutions and ICT service providers can turn increasingly complex due diligence requirements into more efficient, trusted and scalable working relationships.
The FTL initiative addresses a practical challenge encountered across the sector. Bespoke questionnaires, duplicate evidence requests and fragmented exchanges can make both initial onboarding and ongoing oversight resource-intensive, against a background of increasing regulatory requirements for ICT and third-party risk management. FTL’s objective is not to reduce scrutiny or regulatory accountability, but to remove avoidable friction and duplication by establishing a common, risk-based baseline that supports proportionality, transparency, evidence reuse and constructive dialogue.
From a shared challenge to a common framework
FTL’s membership developed the initiative, mobilising around 25 volunteers and bringing together legal, compliance, security, risk and operational expertise. Competing companies chose to work together transparently on shared operational challenges, turning their experience into a concrete and reusable framework. FTL warmly thanks all participants in the project group for their time, expertise and commitment. The resulting package provides an operational foundation that will continue to be refined through implementation and practical experience.
A practical due diligence package
The work has resulted in one common due diligence package made up of three complementary components: the Due Diligence Charter, a Standard Questions Repository and a Document List with proportionate disclosure tiers.
The Due Diligence Charter is a voluntary and non-binding industry framework built around ten principles. These cover proportionality and risk-based scoping, precision and mutual transparency, recognition and reuse of existing evidence, controlled transparency and data protection, internal coordination, constructive engagement, regulatory complementarity, responsible use of technology and AI, and continuous ecosystem improvement.
Adherence to the Charter does not constitute certification, accreditation, audit or regulatory approval by FTL. Nor does it replace legal, regulatory, supervisory or contractual requirements or transfer responsibility for regulatory compliance. Each financial entity remains responsible for its own assessment and decision-making.
The Standard Questions Repository translates these principles into an operational baseline. It comprises 225 standard questions structured into 17 chapters and 57 topic domains. Questions are applied according to the risk profile of the ICT engagement, covering baseline requirements, services supporting critical or important functions, and the processing of personal data. These categories structure the use of the FTL framework; they are not regulatory thresholds or a common scoring model.
The third component is a Document List covering 93 evidence artefacts, organised into three disclosure tiers: Core, Extended and Restricted. The underlying principle is straightforward: access to information increases with the identified need. The model is intended to facilitate appropriate access to evidence while protecting confidentiality, security and intellectual property.
Industry momentum and CSSF encouragement
The conference formally welcomed the first 19 organisations to sign the Charter, marking the initiative’s official launch and providing an early indication of industry engagement.
Addressing the audience, Claude Marx, Director General of the CSSF, brought the supervisory perspective to the discussion on trusted and effective ICT relationships. He acknowledged and encouraged the initiative, highlighting the continuous and constructive dialogue between the CSSF and FTL throughout the year.
The Charter nevertheless remains a voluntary, industry-led and non-binding framework. It does not constitute certification or regulatory guidance, and adherence does not in itself demonstrate regulatory compliance.
From compliance to collaboration
The broader conference programme placed the initiative within the wider question of how Luxembourg can strengthen trust and resilience across its financial and technology ecosystem. Jean-Hubert Antoine, Board Member of FTL and Co-Chair of the Project Group on Due Diligence, presented the Due Diligence Charter project alongside Céline Henck, Head of Enterprise Information Security and Compliance at Proximus Luxembourg, and Valentina Rigatti, Legal and Compliance Director at NSI Group, both contributors to the project group.
A roundtable brought together financial-sector, technology, risk, compliance and legal perspectives on the transition from compliance-driven exchanges to trusted, scalable partnerships. The programme concluded with remarks by FTL Vice-Chairman Laurent de la Vaissière.
The discussion reflected the broader ambition behind the Charter: regulatory requirements remain each organisation’s responsibility, but cooperation between clients and providers can make the operational processes used to meet them more consistent, proportionate and reusable.
An evolving initiative: FTL calls for further organisations to join
The Charter and its supporting deliverables are intended to evolve through practical implementation, feedback from signatories and continued dialogue across the financial and technology ecosystem. FTL’s next phase will focus on broadening participation and deepening engagement with clients and financial institutions.
Call for signatories
FTL now invites eligible organisations across Luxembourg’s financial and technology ecosystem to discover the Charter, join the initiative, become signatories and contribute to its continued development. Broader participation will help refine a shared approach that makes ICT due diligence more efficient and proportionate while preserving the scrutiny, accountability and risk management expected of each organisation.
Further information on the Charter and the process for becoming a signatory is available on the FTL Due Diligence Charter webpage. Organisations wishing to join must complete and sign the Declaration of Adherence and meet the applicable eligibility conditions.
FTL thanks Intesa Sanpaolo Servitia for hosting and supporting the Annual Conference, and its media partner ITnation for supporting the event.
