The LBR (Luxembourg Business Register) is implementing a new requirement for all Luxembourg entities and specifically regarding the natural persons registered within their files (manager, director, partner, shareholder, day-to-day manager, auditor, etc.).
Purpose
Persons and entities registered with the RCS (Luxembourg Trade and Companies Register) will have to communicate the Luxembourg national identification number – "LNIN" (also known as a "CNS number or "matricule") of all natural persons registered with the RCS. Once provided to the RCS, the LNIN will not be publicly accessible.
Existing and future entities must therefore be updated, for natural persons resident and non-resident in Luxembourg.
For natural persons who are not Luxembourg residents, the RCS will proceed to assign LNIN number when registering a new entity or filing a change in the relevant entity.
The following additional information must be provided for this purpose:
- Nationality
- Gender
- Private residence
This information will not be registered in the RCS and published but will be transmitted to the National Register of Natural Persons.
Effective date/transition period
This new procedure will be available as from 12 November 2024. A transitional period of several months will be available to comply with these new requirements based on the initial guidelines received from the LBR.
After this transitional period, filing processes for a legal entity will be blocked if the LNIN of all natural persons of the registered entity have not been provided. Arendt strongly recommends that registered entities communicate the missing LNIN of natural persons registered in their file as soon as possible or contact Arendt for support with obtaining them.
In addition, the new RCS formalities may also prompt an obligation to update the information registered with the Register of Beneficial Owners with the LNIN created in RCS for the natural persons who are also registered with the Register of Beneficial Owners.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
