RCS/RBE compliance in Luxembourg: the LBR will begin ITS enforcement phase from 21 September 2026

The Luxembourg Business Registers (LBR) has announced the launch, with effect from 21 September 2026, of a new phase of checks and sanctions aimed at ensuring the accuracy of the data entered in the ‘Registre de Commerce et des Sociétés‘ (RCS) and the ‘Registre des Bénéficiaires Effectif’s (RBE). Entities registered in Luxembourg whose information is incomplete, inaccurate or out of date now face a range of progressive measures, ranging from a simple warning to automatic striking off.

This article provides an overview of the current obligations, the precise timetable for sanctions and the steps to be taken to rectify one’s situation.

Why is the LBR stepping up its checks?

Entities registered with the RCS and the RBE are legally obliged to maintain accurate, complete and up-to-date information. This requirement forms part of the fight against money laundering and the financing of terrorism, but also serves the broader objective of ensuring the reliability and transparency of the Luxembourg register.

Until now, any breaches identified were followed up with reminders, without any real structured sanction mechanism. With this new phase, the LBR is introducing a graduated and binding procedure.

How does the compliance procedure work?

When the LBR identifies a breach on date T, a registered letter is sent to the entity concerned, to the address of its registered office as recorded in the RCS. The entity then has 30 days to rectify the situation.

If the situation is not rectified within this period, penalties are applied progressively.

Schedule of penalties in the event of failure to rectify the situation

Why is the letterbox at the registered office so important?

Key point: the registered letter from the LBR is sent to the registered office address listed in the RCS. If the letter cannot be delivered (no letterbox, unlabelled letterbox, or incorrect address), the penalty proceedings will continue regardless.

Worse still: the absence of an actual registered office at the declared address may, in itself, constitute a further breach, regardless of the initial issue that triggered the proceedings.

Key point: it is essential to ensure that the letterbox at the registered office is correctly labelled and regularly emptied, including for organisations using a registered office service.

Are non-profit organisations and foundations affected?

At this stage, non-profit organisations (ASBL) and foundations are not affected by the initiation of these sanction proceedings. However, this exclusion may change; it is advisable to keep an eye on any further communications from the LBR on this matter.

How to check and update your RCS/RBE details?

To avoid any risk of penalties, entities registered in Luxembourg are advised to:

1. Check the accuracy of the information entered in the RCS (registered office, management bodies, corporate purpose, etc.);
2. Check that the RBE is up to date, particularly in the event of a change in ownership or control structure;
3. Ensure that the registered office is accessible and that the postbox is functioning properly;
4. Anticipate any changes (relocation, change in shareholding, etc.) by reporting them without delay.

Are you unsure whether your RCS/RBE data is compliant? Contact us to have your records checked before the penalties come into force.