Although the exact date on which this new obligation shall take effect is not yet known, it is expected that this requirement will become applicable as at the end of the first quarter of 2022 (the “Effective Date”).
This new requirement applies to both Luxembourg resident and non-resident individuals, regardless of their capacity (director, manager, shareholder, auditor, etc.). It also applies to individuals already registered with the RCS before the Effective Date as well to individuals who will have to be registered after the entry into Effective Date.
As this is personal data, the LNIDN registered with the RCS will not be communicated to third parties, nor will it appear on pre-filled requisition forms or be available on the dedicated RCS portal.
Individuals who are to be registered with the RCS
- Individuals who already possess an LNIDN (or shall possess it prior to the Effective Date) will need to communicate it to the RCS upon filing with the RCS.
- Individuals who do not possess a LNIDN (or shall not possess it upon Effective Date) shall need to submit additional documents and information (e.g. nationality, gender, private address) to the Luxembourg Business Register for the sole purpose of creating the number in the National Register of Natural Persons. Such individuals may further appoint a special proxy to represent them in the registration procedure.
Individuals who are already registered with the RCS
For individuals who are already registered with the RCS (or shall be registered prior to the Effective Date), their LNIDN may be registered with the RCS on a voluntary basis for a transitional period before this process becomes mandatory in a second phase.
Contact
Any questions on how to proceed? Please do not hesitate to contact our Corporate Team.
[1] Please see hereafter : https://www.lbr.lu/mjrcs/jsp/webapp/static/mjrcs/en/mjrcs/pdf/communication_public_HTML_et_RNPP.pdf
