Since September 21, 2026, Luxembourg Business Registers (LBR) has been gradually rolling out the enforcement phase of its procedure for verifying the data recorded in the Trade and Companies Register (RCS) and the Register of Beneficial Owners (RBE). This phase targets entities that have failed to meet their filing obligations. Non-profit associations and foundations are excluded for now.<\/p>\n\n\n\n
The first registered letters requesting compliance are now being sent to the companies concerned.<\/p>\n\n\n\n
Business leaders need to be especially vigilant: an administrative irregularity can have financial, banking and commercial consequences.<\/p>\n\n\n\n
The law of January 23, 2025, which came into force on February 1, 2025, strengthened the supervisory powers of Luxembourg Business Registers. After an awareness-raising period, the LBR launched its sanctions phase on September 21, 2026. The aim is to improve the reliability and accuracy of the information held in Luxembourg's official registers.<\/p>\n\n\n\n
According to reports in the Luxembourg press, nearly 60,000 files showed at least one breach of filing obligations as of August 31, 2026.<\/p>\n\n\n\n
The most common breaches include:
\u2022 Failure to file annual accounts.
\u2022 An incorrect or incomplete registered office address.
\u2022 Outdated appointments of managers or directors.
\u2022 Missing or inconsistent beneficial ownership information.<\/p>\n\n\n\n
When an irregularity is identified, the LBR may send a registered letter titled \"Request for verification and update\" (Demande de v\u00e9rification et de mise \u00e0 jour). This letter specifies the items that need to be corrected.<\/p>\n\n\n\n
The company has an initial period of 30 days from the date the registered letter is sent to make the requested corrections. Failure to actually receive the letter does not necessarily suspend the procedure.<\/p>\n\n\n\n
If the situation is not corrected, the procedure provides for several escalating measures:
\u2022 From the first day of the second month after the letter is sent: publication of a warning on the LBR website.
\u2022 From the first day of the third month: the breaches are noted on certificates issued by the LBR.
\u2022 From the first day of the seventh month until the last day of the ninth month: a possible penalty of \u20ac40 per day, up to a maximum of 90 days.
\u2022 From the first day of the twelfth month: possible ex officio removal from the register, without dissolution of the company. The file may also be referred to the State Prosecutor.<\/p>\n\n\n\n
The penalty can amount to \u20ac3,600. Ex officio removal does not result in the dissolution of the entity or the loss of its legal personality. It can nevertheless cause significant practical and commercial difficulties. The measures may be appealed in accordance with the procedures and deadlines set out in the applicable legislation.<\/p>\n\n\n\n
The company can correct its situation at any stage of the procedure. Full regularisation ends the procedure and lifts the measures taken, without prejudice to any penalties already incurred.<\/p>\n\n\n\n
RCS extracts are routinely used by banks in their know-your-customer (KYC) procedures, as well as by investors, business partners and potential buyers.<\/p>\n\n\n\n
An irregularity appearing on an official extract may raise questions when opening a bank account, applying for financing, carrying out an investment, acquiring or selling a business, or undergoing a compliance check by a partner.<\/p>\n\n\n\n
A missed administrative obligation can therefore become a strategic risk for the business.<\/p>\n\n\n\n
Yes. Being domiciled does not exempt a company from its legal obligations. However, when a company is domiciled with a service provider that handles its mail, it benefits from an arrangement that makes it easier to keep track of official correspondence.<\/p>\n\n\n\n
At Omnitrust, we receive the mail of companies domiciled with us and inform the clients concerned when action is required. Regularisation may then require additional documents or information from the company's directors.<\/p>\n\n\n\n
1. Check the registered office address recorded in the RCS.
2. Verify that the annual accounts have been filed.
3. Check the information about the company's directors and managers.
4. Make sure the RBE entries are accurate.
5. Forward any letter received from the LBR to your account manager without delay.<\/p>\n\n\n\n
Our teams help businesses meet their accounting and administrative obligations. If you receive a compliance letter, we can review the irregularities reported, identify the documents required, prepare the regularisation formalities and support you in your dealings with the LBR.<\/p>\n\n\n\n
Have you received a letter from the LBR, or would you like to check your RCS or RBE file? Contact your Omnitrust account manager to review your situation.<\/p>\n\n\n\n
Sources: Luxembourg Business Registers, public notice of September 9, 2026; law of January 23, 2025; amended law of December 19, 2002.<\/p>\n\n\n\n
This article provides general information and does not constitute legal advice tailored to any particular situation.<\/p>","protected":false},"excerpt":{"rendered":"
Depuis le 21 septembre 2026, Luxembourg Business Registers (LBR) a engag\u00e9 progressivement la phase coercitive de sa proc\u00e9dure de contr\u00f4le des donn\u00e9es inscrites au Registre de commerce et des soci\u00e9t\u00e9s (RCS) et au Registre des b\u00e9n\u00e9ficiaires effectifs (RBE). Cette phase concerne les entit\u00e9s pr\u00e9sentant des manquements \u00e0 leurs obligations d\u00e9claratives, \u00e0 l’exclusion, \u00e0 ce stade, […]<\/p>\n","protected":false},"author":1,"featured_media":6703,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[1],"tags":[],"service_lie":[],"type_contenu":[],"class_list":["post-6701","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-uncategorized"],"acf":[],"_links":{"self":[{"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/posts\/6701","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/comments?post=6701"}],"version-history":[{"count":2,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/posts\/6701\/revisions"}],"predecessor-version":[{"id":6704,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/posts\/6701\/revisions\/6704"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/media\/6703"}],"wp:attachment":[{"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/media?parent=6701"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/categories?post=6701"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/tags?post=6701"},{"taxonomy":"service_lie","embeddable":true,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/service_lie?post=6701"},{"taxonomy":"type_contenu","embeddable":true,"href":"https:\/\/www.omnitrust.lu\/en\/wp-json\/wp\/v2\/type_contenu?post=6701"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}