New LNIN filing rules – Important update

At a glance

Starting 1 June 2025, filing the Luxembourg National Identification Number (LNIN) will incur costs set by the Luxembourg Trade and Companies Register (RCS).

Furthermore, as of 1 October 2025, all filings of entities that are not compliant with the LNIN filing formalism will be blocked by the RCS.

A closer look

In a recent public notice issued by the RCS on 3 March 2025, significant changes have been announced regarding the filing formalism of LNIN. The transitional period that allowed all registered persons and entities to obtain and file the LNIN for any natural person listed in their file free of charge is coming to an end. Effective from 1 June  2025, the RCS will charge fees for the LNIN filing.

Furthermore, as of 1 October 2025, entities failing to comply with the LNIN filing formalism will face access restrictions to any kind of filing processes. Specifically, the RCS reserves the right to deny non-compliant entities the ability to undertake essential administrative actions; this would include changes in address, share capital updates, annual account filings, and merger projects, for example.

As a reminder, the LNIN filing formalism applies to all natural persons in any capacity, including partners, agents, and auditors; there are exceptions for judicial representatives in RCS-registered procedures or agents of foreign companies with a branch in Luxembourg.

To facilitate compliance, the RCS portal offers a designated filing form. This form allows individuals who already have a LNIN to communicate it and enables those without a LNIN to request its creation.

Applicants are required to provide details regarding nationality, gender, and private residence. Supporting documents for identity verification and proof of residence must also accompany the application.

The information provided will be forwarded to the State Information Technology Centre for inclusion in the National Register of Natural Persons; however, it will not be recorded with the RCS. The LNIN will be issued via email from the State Information Technology Centre directly to the individual, unless the individual has authorized the applicant to receive it on their behalf.

It is important to note that the LNIN, along with information concerning gender, nationality, and private address, will remain private. This data will not be shared with third parties, displayed on pre-filled requisition forms, or accessible through the RCS online portal.

How Deloitte can help

To prevent any disruptions in your entity’s administration and operations, it is strongly advised to complete all necessary actions for the LNIN filing. Our Corporate Secretarial team is ready to assist throughout the process. We can help with the following:

• Registering the LNIN for natural persons
• Applying for the LNIN on behalf of natural persons

Get in touch

HANA WITZKE 
Partner | Corporate & Accounting Services
Tel: +352 621568317
hwitzke@deloitte.lu

MAGDALENA DEDIU 
Senior Manager | Corporate & Accounting Services
Tel: +352 621716369
adediu@deloitte.lu