Everything You Need to Know About the New LNIN Requirement for Filing in Luxembourg, Effective 12 November 2024
A significant legal change is set to take effect in Luxembourg on 12 November 2024, impacting all individuals registered with or about to be registered with entities in the Luxembourg Trade and Companies Register (RCS). From this date, all natural persons associated with an RCS-registered entity must communicate or request a Luxembourg National Identification Number (LNIN).
What is the LNIN?
The LNIN, also known as the “matricule number” or “CNS number“, is a unique identification number issued by the National Register of Natural Persons. It is required for all natural persons connected to any entity listed in the RCS. For individuals already engaged in paid professional activities in Luxembourg, this will typically be their social security number. Individuals who do not have an LNIN will need to request one via a specific process.
Who is Affected by the LNIN Requirement?
The new requirement applies to all natural persons involved in an RCS-registered entity, including:
- Managers
- Directors
- Shareholders
- Statutory Auditors
- Permanent Representatives of a legal person appointed as Manager or Director
However, there are a few exceptions, such as judicial representatives and agents of foreign companies opening branches in Luxembourg.
New Filing Requirements
For those already holding the necessary identification number, the number will need to be provided along with usual personal details (e.g., surname, first names, date, and place of birth). No supporting documentation is required to prove the LNIN.
For those without an LNIN, the creation of this number must be requested as part of the RCS filing procedure. To create an LNIN, additional documents must be provided, including proof of identity (passport or national ID card) and proof of address.
Transitional Period and Consequences for LNIN Non-Compliance
A transitional period will be in place for those already registered with the RCS before 12 November 2024, allowing entities to update their records free of charge. After this period, providing the necessary identification number will be mandatory, and failure to do so could block essential filings, such as:
- Address changes
- Share capital updates
- Annual account filings
- Merger projects
Additionally, the Luxembourg Register of Beneficial Owners (RBE) will also need to be updated with the LNIN for individuals registered in the RBE.
Filing Formalism and New Services
From 12 November 2024, new features will be added to the RCS portal, making it possible to update or request the LNIN for natural persons, either as part of a filing or as a separate procedure. The process will ensure that all required LNINs are communicated, and the filing procedure cannot be completed without it.
How We Can Assist
Navigating this new requirement may be complex, but through Klea’s services, we can handle the entire process for you, ensuring that all filings are compliant and deadlines are met. Our team will assist by:
- Registering the LNIN with the RCS;
- Requesting the LNIN on behalf of any natural person who does not yet have one.
Let Klea manage this process for you, ensuring a smooth and compliant transition. If you or your clients are impacted by this new requirement, feel free to reach out—we’ll handle it from here.
