Luxembourg entities face escalating sanctions - from public warnings to deregistration - for inaccurate RCS and RBE filings. As of 21 September 2026, the Luxembourg Business Registers (“LBR”) is progressively rolling out the sanctions phase of its compliance mechanism for the Luxembourg Trade and Companies Register (“RCS”) and the Register of Beneficial Owners (“RBE”). Companies must now pay particular attention to the accuracy and currency of their registered information.
This new phase follows the Luxembourg law of 23 January 2025, which strengthened LBR's mandate to monitor and enforce compliance. It aims to improve the quality, reliability, and integrity of registered data, so that public authorities, economic operators, and other users can rely on accurate, up-to-date, and directly usable information on entities registered in Luxembourg. Nonprofit organisations (ASBLs) and foundations are not, however, subject to enforcement proceedings at this stage, as awareness-raising efforts are still underway.
From automated checks to formal enforcement
Since January 2026, LBR has implemented an automated process for monitoring the RCS and RBE databases, in order to detect erroneous or outdated data, the failure to record data required by law, or the failure to file a required document.
As a reminder, data recorded in the RCS or the RBE must be adequate, accurate, and current, in accordance with Article 1 of the amended law of 19 December 2002 on the register of commerce and companies as well as the accounting and annual accounts of undertakings (the "RCS Law"), and Article 4 of the amended law of 13 January 2019 establishing a Register of Beneficial Owners (the "RBE Law").
LBR initially adopted a preventive approach: automated reminders by email, communication, support, and the option for entities to voluntarily regularise their situation.
After several months devoted to this phase, LBR is now moving to the sanctions phase.
What happens when a deficiency is identified?
Where LBR identifies one or more deficiencies in the file of a registered entity - namely that information is missing, outdated, or incorrect, or that a filing required by law has not been made - it sends the person or entity concerned a request by registered letter to regularise its file.
The date on which this letter is sent, referred to as "Date T", marks the starting point of the procedure.
The update request:
lists all the deficiencies identified by LBR, based on automated data monitoring;
reminds the entity of the 30-day period within which to fully regularise its file, before the administrative measures and sanctions become applicable;
informs the registered entity of the various administrative measures and sanctions it may face if it fails to update its file as soon as possible;
indicates the remedies available to the registered entity that wishes to challenge LBR’s decision.
The entity then has 30 days from Date T to regularise its file.
Failing that, the measures set out below will be progressively implemented and will accumulate depending on the time elapsed since Date T:
T + 30 days - a warning is displayed on the LBR portal.
T + 60 days - outstanding deficiencies appear on RCS/RBE extracts and certificates.
T + 7 months - a daily penalty of EUR 40 applies, for a maximum of 90 days, i.e. up to EUR 3,600.
T + 12 months - ex officio deregistration.
After deregistration - referral to the State Prosecutor and, where the statutory conditions are met, potentially a PDAL (procédure de dissolution administrative sans liquidation).
It is important to bear in mind that the procedure continues even if the registered letter is not actually delivered, and the absence of an effective registered office can itself constitute a deficiency.
It is never too late to regularise
The entity may regularise its file at any stage of the procedure.
If all deficiencies are regularised:
the procedure ends immediately;
the measures already applied are lifted, in accordance with the applicable legal provisions;
however, any penalty payment already accrued remains due.
In the event of only partial regularisation, the procedure continues until full regularisation is achieved. Any new deficiencies identified during the course of the procedure may also be added to it.
Administrative decisions taken by LBR in connection with the compliance procedure may be appealed before the Lower Administrative Tribunal (Tribunal administratif) within a period of three months.
Why this matters for your business
The launch of the sanctions phase represents a fundamental shift from voluntary compliance to active enforcement. For Luxembourg entities, the practical implications are significant: inaccurate or outdated filings will no longer be treated as mere administrative oversights. Public warnings on the LBR portal, annotations on official extracts and certificates, daily penalties of up to EUR 3,600, and ultimately ex officio deregistration create real reputational and operational risks. Boards and compliance teams should treat this as a priority: audit your RCS and RBE filings now, verify that all registered information is current, and establish internal processes to keep filings up to date on an ongoing basis.
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