Update to LNIN in Luxembourg

On March 3, 2025, the Luxembourg Business Registers (“LBR”) announced upcoming changes to filing requirements concerning Luxembourg national identification numbers (“LNINs”).

Starting November 12, 2024, all submissions to the Luxembourg Trade and Companies Register ("RCS") must include an LNIN for every individual associated with a registered entity. This includes managers, directors, shareholders, partners, auditors, and authorised representatives.

Updates will be free until May 31, 2025, after which a fee will be imposed from June 1, 2025.

Crucially, from October 1, 2025, the LBR may block filings for entities that have not updated their LNINs. These restrictions will remain until the necessary information is provided.

Immediate action is advised to prevent any disruptions.

Key Deadlines

• The last day to update LNINs free of charge is 31 May 2025;

• From 1 June 2025, a EUR 10.96 (excluding VAT) fee per update applies; and

• From 1 October 2025, the LBR may block filings (of financial statements, for example) for entities missing the required LNINs.

  Action required

To ensure compliance and avoid disruptions, all affected individuals and entities should do the following:

• Check whether they already have an LNIN;

• Request an LNIN if they do not have one; and

• Submit the LNIN to the RCS if it is missing from their records before the transitional period ends.

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.

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.