New CNC Q&A 26/038 – Clarifications on the new accounting regime introduced by the Law of 7 August 2023 for large associations, associations recognised as being of public utility and foundations

At a glance

On 21 July 2026, the Luxembourg Accounting Standards Commission (CNC) issued Q&A CNC 26/038 providing targeted clarifications on the accounting regime introduced by the Law of 7 August 2023 for:

• not‑for‑profit associations classified as large associations;
• associations recognized as being of public utility; and
• foundations.

A closer look

The CNC confirms that these entities are now subject to the regime applicable to medium‑sized undertakings under the article 47 of the Law of 19 December 2002 on the Trade and Companies Register and the Accounting and Annual Accounts of Undertakings (LRCS). As a result, they are required to prepare annual accounts comprising, at a minimum, a non‑abridged balance sheet, an abridged (or optionally, non‑abridged) profit and loss account, and notes to the accounts containing the disclosures required under the LRCS.

Large associations, associations recognized as being of public utility, and foundations are exempt from the mandatory use of the Standard Chart of Accounts (Plan Comptable Normalisé - PCN) and the eCDF financial data collection platform. Accordingly, filings with the Luxembourg Trade and Companies Register (RCS) must continue to be made using the traditional filing format.

Nevertheless, the CNC confirms that these entities may choose to adopt the PCN voluntarily. This may offer practical benefits, including access to predefined mapping tables and opportunities to simplify or automate the preparation of balance sheet and profit and loss account disclosures. By contrast, entities that maintain their own internal chart of accounts should ensure that robust and well-documented mappings are in place between their internal accounts and the statutory balance sheet and profit and loss account formats, both to support financial reporting and facilitate audit procedures.

The CNC also clarifies that, while these entities are required to use the standard balance sheet and profit and loss account layouts prescribed by Articles 34 and 47 of the LRCS, they remain free to adapt the nomenclature, structure and terminology of individual line items, within certain limits, to better reflect the nature of their activities.

In light of these clarifications, affected entities should review their current chart of accounts and filing processes, decide whether voluntary adoption of the PCN would be beneficial from an operational and audit perspective, and, where an internal chart of accounts is retained, ensure that an up‑to‑date  and documented mapping to the statutory formats is established and embedded within year‑end reporting procedures.

Looking ahead, the CNC has announced that it intends to publish a dedicated accounting guide in autumn 2026 covering the new regime applicable to small, medium-sized and large non-profit, as well as to public-utility associations and foundations. This guide is expected to provide practical support stakeholders in implementing and applying the revised accounting framework.