Delegation and Supervision : Are You Truly Able to Supervise Your Delegates?

In Luxembourg’s financial and corporate landscape, delegation has become the norm: portfolio management, distribution, central administration … Almost everything can be delegated - everything - except responsibility.

The CSSF keeps repeating it: the delegation does not remove your duty to supervise. Yet, in practice, supervision is still too often the exception. At Osmia Consulting, we help stakeholders turn this regulatory obligation into a true governance asset, strengthening one of the most critical pillars of long-term success.

What the CSSF Really Expects

• Due diligence
  A thorough preliminary review of delegates, including initial due diligence, assessment of specific risks, and approval by the relevant governing bodies.

• Contracts
  A clear contractual framework defining access rights, reporting commitments, and transparencyobligations.

• Monitoring
  A documented monitoring system, including the analysis of periodic reports, formalized meetings, and systematic follow-up on corrective actions.

Common Weaknesses

• Passive or absence of monitoring
  Receiving a report is not supervision. The report must be reviewed, questioned, and followed by concrete action.

• Vague roles and responsibilities
  Who supervises what? The Board, the RR, the RC? Too many structures lack a clear allocation of responsibilities.

• Lack of concrete evidence
  The CSSF is not only interested in what is done, but in what can be demonstrated and documented.

How to Strengthen Supervision

• Formalize monitoring committees, with agendas, minutes, and clear action plans.

• Define key indicators - such as KPIs, incidents, and contractual compliance - tailored to each type of delegation.

• Act proactively: don’t wait for the annual report to respond. Implement alerts, hold quarterly meetings, and conduct targeted site visits when necessary.

Supervision is not about ticking boxes. It requires an active, critical, and ongoing approach.
Osmia Consulting helps its clients shift from a model of blind trust to one of enlightened, proportionate, and demonstrable supervision.

How can Osmia Consulting help you?

We combine deep regulatory expertise with hands-on experience.
Working in close partnership with our clients, we tailor practical, effective solutions that are fully aligned with CSSF expectations - and that work in practice, not just on paper.

Partner with Osmia Consulting to elevate your governance so your board can focus on what matters most: steering the organization toward long-term success. Contact us to find out how we can support your governance needs.