New RCS requirement - Introduction of the Luxembourg National Identification Number (LNIN)

The Luxembourg Business Register (“LBR”, the "Register") has announced that starting from 12 November 2024, any individual registered or to be registered with the LBR in roles such as manager, director, partner, shareholder, auditor, or authorised person, must provide their Luxembourg National Identification Number (“LNIN”) to the Register. This requirement derives from Article 12bis of the Luxembourg law dated 19 December 2002 concerning the RCS and the bookkeeping and annual accounts of companies, as amended.

The LNIN can be registered through either the standard filing process by completing the dedicated field requesting the LNIN confirmation, or on a voluntary basis by updating the natural person’s registered information on the RCS online portal.

The request may be made either by the natural persons themselves or by the person in charge of the filing process relating to the legal entities to which these natural persons are linked.

To obtain an LNIN, the following information and supporting documents must be provided regarding the natural person registered or to be registered with the RCS:

• Their last name, first name(s), date, place and country of birth, gender, nationality and full private address;

• A copy of their valid passport or ID;

• An accepted document evidencing their private address dated within the last six months; and

• A free translation into French, German, Luxembourgish or English of the two documents above if they are in another language.

Information related to the gender, nationality and private address is not registered with the RCS, but with the National Register of Natural Persons.

This information will not be registered with the RCS but will be directly transmitted to the Centre des technologies de l’information de l’Etat for integration into the database.

The LNIN assigned by the RCS is not public. The natural person for whom the number has been created will receive it by mail at their private address shared with RCS.  For Luxembourg residents their “matricule” number has to be shared with the Register.

Transitional Period and Consequences for LNIN Non-Compliance

Entities registered with the RCS before November 12, 2024, will have a transitional period to update their records for free. After this timeframe, it will be compulsory to provide the required identification number. Failure to do so may result in the inability to complete essential filings, including:

• Address changes;

• Share capital updates;

• Annual account filings; and

• Merger projects.

Additionally, the Luxembourg Register of Beneficial Owners (“RBE”) will also need to be updated with the LNIN for individuals registered in the RBE.

How We Can Help

At Cafico International, we can assist you with the registration or amendment of a person with the RCS, request a LNIN for an individual that does not currently possess one and update any information of an individual in the RCS who is in receipt of a LNIN. For more information, please reach out to Arek Kwapien.