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Luxembourg entities must now ensure that all natural persons listed in their RCS filings have a valid Luxembourg National Identification Number (LNIN). The transitional period has ended, and stricter enforcement measures are about to apply.
What has changed since the initial introduction?
The requirement to provide a Luxembourg National Identification Number (LNIN) for each natural person linked to an RCS entity began on 12 November 2024. Companies enjoyed a transitional period to update records without cost. That window has now closed, and the LBR will enforce compliance.
What happens from 1 October 2025?
From this date, LBR blocks access to filing services if an entity still lacks LNIN details for all natural persons. The block remains until the entity regularises its records. As a result, companies cannot submit essential filings, such as annual accounts, registered office changes, or director updates.
Which deadlines should companies remember?
The free update period ended on 31 May 2025. Since 1 June 2025, companies must pay filing fees for LNIN updates. The transitional period ends on 30 September 2025, with full enforcement starting on 1 October 2025.
Who needs to have an LNIN?
Every manager, director, shareholder, statutory auditor, and permanent representative listed in RCS filings must hold an LNIN. Companies that fail to provide these numbers risk immediate suspension of their filing rights.
How can companies prepare effectively?
Compliance teams should review their RCS files now. They should confirm that every listed person has a valid LNIN. Where records are incomplete, teams must request or register missing numbers quickly. By acting before the October deadline, companies avoid disruptions and ensure smooth access to filing services.
What’s next?
Managing an RCS filing requires detailed planning and full legal awareness. For more insights into processes in other jurisdictions, explore our article, Everything You Need to Know About the New LNIN Requirement for Filing in Luxembourg, Effective 12 November 2024.
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The information provided on Klea’s website is made available “as is” for informational purposes only. Klea does not provide legal, tax, or financial advice and is not responsible for any actions taken or not taken based on the content found on this website. In no event shall Klea be liable for any loss or damages arising from reliance on the information contained herein.
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