In brief
On 21 September 2026, the Luxembourg Business Register started the progressive roll out of the enforcement phase of its procedure for monitoring and ensuring compliance of data registered with the Trade and Companies Register (RCS) and the Register of Beneficial Owners (RBE). Introduced under the Law of 23 January 2025 the procedure aims to enhance the quality, reliability and integrity of the registered data.
Who is affected?
All entities registered in the RCS and RBE are under scope, and the entities whose records contain one or more points of non-compliance will be affected. Such instances may arise from incorrect, outdated, inconsistent or missing information, or from the failure to complete a mandatory filing or procedure.
Non-profit associations (ASBLs) and foundations are not currently subject to the opening of enforcement proceedings, as awareness-raising and information measures remain ongoing.
How will it work?
For each affected entity, the LBR will send a registered letter identifying the instances of non-compliance and inviting the company to regularise its file. The date on which the letter is sent is the “T date”. If the file is not regularised within one month, the following cumulative measures apply:
| Deadline | Stage and measure |
| T date + 30 days | Display of a warning A warning is displayed on the LBR portal when the entity file is consulted publicly. |
| T date + 60 days | Reference on extracts and certificates Outstanding instances of non-compliance are stated on extracts and certificates issued by LBR |
T date + 7 months
|
Penalty payment A daily penalty payment of EUR 40 is imposed for a maximum of 90 days, up to EUR 3,600 |
| T date + 12 months | Deletion ex officio LBR deletes the entity from the register ex officio. This does not dissolve the entity nor causes it to lose its legal personality |
| After deletion ex officio | Possible further actions The file may be referred to the State prosecutor. If the legal requirements are met, the entity may also become subject to administrative dissolution without liquidation (PDAL). |
Regularisation
An entity may rectify its file at any point during the proceedings. Upon full regularisation of all identified non-compliance issues, the proceedings shall terminate and all measures imposed shall be lifted, without affecting any financial consequences resulting from measures already enforced.
Examples of potential non-compliance situations[1]
Outdated registered office, management or beneficiary information.
Missing mandatory RCS updates following corporate changes.
Missing mandatory RBE updates following corporate changes.
Inconsistencies between RCS and RBE records.
Outstanding filing obligations (e.g. annual accounts, consolidated accounts or other mandatory corporate filings).
Incomplete or inaccurate corporate data maintained in the registers.
[1] Luxembourg Business Registers, Guide to the monitoring and compliance procedure, available on the LBR website, here.
How can PwC Luxembourg assist?
At PwC Luxembourg, we help you stay compliant by identifying and addressing filing and reporting gaps, supporting remediation efforts and assisting with the regularisation of corporate records following a compliance notification letter.
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
