New RCS formalities – new deadline announced

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 an 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 has been available since 12 November 2024. A transitional period of several months is available to comply with these new requirements based on the initial guidelines received from the LBR.

If the LNINs are not provided, the LBR reserves the right to restrict access to the filing formalities for the entities concerned until these numbers have not been communicated to the LBR and their situation has been regularised.

This restriction will apply from 1 October 2025, the date on which the blocking of filings comes into effect.

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 the RCS for the natural persons who are also registered with the Register of Beneficial Owners.