New online RCSL requisition forms
In line with the LBR’s objective to enhance digitalisation and facilitate the RCSL registration process, the traditional PDF requisition forms will be replaced by forms to be completed directly online in HTML format.
Registration of Luxembourg NIN for natural persons registered with the RCSL
The new online requisition forms will enable the implementation of article 12bis of the Luxembourg law of 19 December 2002 on the RCSL and the accounting and annual accounts of companies, as amended (the “2002 Law”) according to which the Luxembourg NIN of any individual registered with the RCSL in any capacity whatsoever (such as a shareholder, manager/director or supervisory auditor…) shall be communicated to the RCSL.
A specific procedure will be set up for individuals who do not have a Luxembourg NIN yet (which is often the case for non-Luxembourg residents) requiring additional information, including nationality, gender, and private residence, to be provided to the RCSL alongside supporting documents (identity card or passport, certificate of residence, utility bill, etc.). The RCSL will then transmit such information to the State Information Technology Centre (Centre des Technologies de l’Information de l’Etat – “CTIE”), which will create a new Luxembourg NIN in the database of the National Register of Natural Persons and will communicate such to the individual (and the depositor should it have received authorisation from the individual).
This new requirement will apply to both new entities and entities already registered with the RCSL. Registered entities will at first not be required to update their files with the RCSL to complete missing Luxembourg NINs for their registered individuals but this will subsequently become compulsory.
March 2025 Update: the LBR announced on 3 March 2025 that the registration of Luxembourg NINs (or “LNIN”) by existing entities for natural persons registered with the RCSL will remain free of charge until 31 May 2025, after which the specific filing for the update of LNINs will be subject to a fee.
Entities and individuals failing to register/update their LNINs by 1 October 2025 may face restricted access to filing formalities. This means that entities may be unable to proceed with any filing with the RCSL until they effectively regularize their LNIN status.
N.B.: The Luxembourg NIN will not be public information, nor will it appear on the RCSL or in RCSL documents.
Automatic consistency check of addresses
Completing the RCSL requisition forms online will also allow an automated consistency check of Luxembourg addresses provided to the RCSL against the information contained in the National Register of Localities and Streets (Registre national des localités et des rues) in accordance with article 12ter of the 2002 Law, ensuring better consistency and accuracy of information registered with the RCSL. This process shall also allow the RCSL to automatically update registered addresses in case of change in the National Register of Localities and Streets.
For any questions, please contact your trusted advisor at Tiberghien Luxembourg or contact any of the authors of this publication.
