New corporate filing formalities for LNIN effective 12 November 2024

At a glance
 

Starting 12 November 2024, all Luxembourg Trade and Companies Register (RCS)-registered entities and individuals must provide the Luxembourg National Identification Number for any natural person listed in their file. For those without an LNIN (LNIN), the necessary data will be collected during the RCS registration process, and the LNIN will be issued via email by the State Information Technology Centre. Initially voluntary and free, updating LNINs will become mandatory, and the absence of a LNIN could potentially block essential filing processes, such as address changes and annual filings.
 

A closer look

According to a recent public notice from the Luxembourg Trade and Companies Register (RCS), all persons and entities registered with the RCS will be required to provide the Luxembourg National Identification Number for any natural person listed in their file.

This new filing formality applies to all natural persons in any capacity, including partners, agents, and auditors, with exceptions for judicial representatives in RCS-registered procedures or agents of foreign companies with a branch in Luxembourg.

From 12 November 2024, when registering a natural person with the RCS, if the individual already has a LNIN (commonly known as a matricula or CNS number), this number must be submitted as part of the filing. For natural persons not in possession of a LNIN, the necessary data to create one will be collected upon submission of the RCS registration application.

In this respect, a designated filing form will be accessible on the RCS portal to facilitate the communication of the LNIN for individuals who already possess one, as well as to enable those without an LNIN to request its creation.

Applicants must provide documents and information regarding the nationality, gender, and private residence. Supporting documents verifying the individual's identity (i.e., identity card or passport) and their private address (e.g., residence certificate, certified declaration of honor, or utility bill) must be included with the application.

This information will be transmitted to the State Information Technology Centre for inclusion in the National Register of Natural Persons but will not be registered with the RCS. Once issued, the LNIN will be communicated by email from the State Information Technology Centre directly to the individual, unless they have authorized the applicant to receive it on their behalf.

The LNIN, along with information on gender, nationality, and private address, will not be public. Furthermore, the LNIN will not be shared with third parties, appear on pre-filled requisition forms, or be accessible on the RCS online portal. For individuals already registered with the RCS, their LNIN information will need to be updated in the RCS system.

Initially, updating the LNIN will be voluntary and free of charge, with a transitional period before this requirement becomes mandatory. After this transitional period, the absence of a LNIN could block any filing processes, such as changes in address, share capital updates, annual account filings, or merger projects.

We strongly recommend initiating the voluntary filing of missing LNINs promptly. Our corporate secretarial team is available to support you through the process, including by (i) registering the natural person's LNIN, and (ii) applying for a LNIN on behalf of the natural person.

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