New filing requirements with the Luxembourg Register of Commerce and Companies

From 12 November 2024, any individual whose details are filed on the Luxembourg Register of Commerce (RCS) has to provide a Luxembourg national identification number (known as the matricule or CNS number) (LNIN).

 

Who falls within the scope of the obligation?

All natural persons appearing in the file of an entity registered with the RCS in any capacity fall within the scope of the new disclosure requirement.

There are two exceptions where the number won't need to be communicated:

• When the natural person is a court-appointed receiver (mandataire judiciaire), appointed in the context of proceedings published on the RCS.
• When the natural person is an agent of a company established in another jurisdiction which has opened a branch in the Grand Duchy of Luxembourg.

 

Filing requirements start from 12 November 2024

From 12 November 2024:

• For any filings in respect of an incorporation / registration of a legal entity with the RCS, all individuals whose information have to be published on the RCS will have to provide the LNIN.
• Any filings regarding changes to information pertaining to individuals (eg change of management) will require the LNIN.
• Any filings of information or in respect of modifications of information which don't pertain to individuals won't require the LNIN before the end of a transitional period (the RCS is yet to confirm the end date of the period).
• Individuals can provide the LNIN voluntarily.

 

How to get an LNIN

In situations where an individual doesn't have an LNIN, they can ask for one to be created as part of the filing procedure with the RCS.

To get an LNIN, individuals will need to provide the following information:

• Last name
• First names
• Date, place, and country of birth
• Gender
• Nationality
• Private home address

Individuals have to submit supporting documents regarding their identity and their private home address to the RCS.

For documents that aren't in French, German, Luxembourgish or English, an unofficial translation will have to be provided.

You can find out more in the notice issued by the Luxembourg Business Registers Filing formalism – new features - To be available soon