New RCS registration requirements for natural persons in Luxembourg

  • October 16, 2024

Update (March 2025)

On 3 March 2025, the Luxembourg Business Register ("LBR") LBR informed that the specific formality of filing with the RCS, which allows the update of the LNIN of natural persons registered with the RCS, will remain free of charge until 31 May 2025.

As from 1 June 2025, this service will be subject to a fee (usual fee for standard non-statutory filing shall apply).

In addition, as anticipated, if the LNINs are not updated by 30 September 2025, LBR reserves the right to restrict access to the filing formalities for the entities concerned until these numbers have been communicated to LBR and their situation has been regularised.

As a consequence, any filing will be blocked for companies that are not in compliance with their LNINs registration obligation as from 1 October 2025 (end of transition period).

In brief

On 6 September 2024, the Luxembourg Business Registers (LBR) announced significant changes to the registration requirements for natural persons associated with entities registered with the Trade and Companies Register (RCS). These changes, effective as from 12 November 2024, require the registration of a “Luxembourg national identification number” for all the natural persons involved with registered entities.

In detail

Who is affected? 

All the natural persons registered with the RCS, in any capacity, including but not limited to:

  • Shareholders, Partners;
  • Directors, Managers;
  • Authorised representatives;
  • Auditors. 

What is the national identification number to be registered?

The Luxembourg national identification number (LNIN), also known as the 'matricule number' or 'CNS number', is a unique identifier for natural persons1.

1 The LNIN is assigned to any natural person having been registered in a Luxembourg public administration (resident, non-resident, Luxembourg national person, employee, independent, etc.) at some point in their life. The attributed LNIN is indefinitely valid.

Information to be provided to the RCS?

  • For natural persons with an existing Luxembourg national identification number:

Provide the LNIN in the dedicated field on the RCS requisition form, along with the usual identification information (first names, last name, date and place of birth). No supporting documents are required.

  • For natural persons without an existing Luxembourg national identification number:

Request the creation of a LNIN by providing the following information:

  • First names;
  • Last name;
  • Date, place and country of birth;
  • Gender;
  • Nationality;
  • Private home address (number, street, postal code, locality, country).

Supporting documents such as ID documents and proof of private address must also be attached to the request.

NB: For documents that are not drawn up in French, German, Luxembourgish or English, a translation (simple, not sworn) must be additionally provided.

Who may access the filed information?

Information on gender, nationality and private address of the natural person will not be registered in the RCS and will not be disclosed to the public but will be sent to the Centre des technologies de l’information de l’Etat for inclusion in the National Register of Natural Persons. They are therefore communicated to the RCS solely for the purposes of creating the LNIN.

The LNIN is not public and will only be sent to the individual, except if the person performing the request on behalf of the individual has been granted with a special proxy and selected the option to receive the LNIN as well.  

Process for registration, filing and/or modification of RCS files

While performing a registration, a filing and / or a modification of an existing file on the RCS:

A specific filing form will be available on the RCS portal for this purpose allowing the communication of the LNIN for those already with an existing one or allowing those without a LNIN to request its creation. It will be carried out outside of a filing procedure with the RCS.

NB: During the transition period (see below), updating LNINs as part of this new service will be free of charge to allow registered entities to quickly update missing information.

What's next?

When will the registration requirement become mandatory? 

As from 12 November 2024, a transitional period will be in place, the duration of which will be communicated later.

During this transitional period, the LNIN must be provided only for a registration or modification linked to a natural person.

Other filings of modifications which do not concern natural persons will still be allowed although the LNIN of the natural persons registered for this entity are not yet communicated to the RCS.

The LNIN will have to be provided for every single entity, despite the fact that the individual is already registered (and provided the LNIN) in other entities or not.

After this transitional period, failure to comply with these new requirements will result in the inability to finalise filing procedures with the RCS, no matter if it relates to a natural person or not (e.g. filing of annual accounts, change of the registered address). 

How PwC Luxembourg can assist?

At PwC Luxembourg, we can assist you throughout the process, (i) to perform the registration of the natural person LNIN, and (ii) to apply for a LNIN on behalf of the natural person.

Contact us

Florent Delory

Tax Partner, Entity Governance & Compliance, PwC Luxembourg

Tel: +352 621 332 667

Mathieu Feldmann

Tax Partner, Entity Governance & Compliance, PwC Luxembourg

Tel: +352 621 335 188

François Guyot

Tax Managing Director, Entity Governance & Compliance, PwC Luxembourg

Tel: +352 621 333 162

Clara Hann

Tax Senior Manager, Entity Governance & Compliance, PwC Luxembourg

Tel: +352 621 334 939