New RCS requirement: introduction of the Luxembourg National Identification Number (LNIN)

A new mandatory requirement is being introduced from 12 November 2024 by the Luxembourg Trade and Companies Register (RCS), through which all natural persons registered within the file of a registered entity must have a Luxembourg National Identification Number (LNIN).

The LNIN is a unique identification number assigned by the National Register of Natural Persons, more commonly known in Luxembourg as the “matricula” or “CNS” number.

The LNIN requirement applies to all natural persons in the file of a registered entity in any capacity, such as for example director, partner, shareholder, agent or statutory auditor.

For those natural persons that have a matricula or CNS number, this will also become their LNIN. But those without one will have to apply for one to be created.

The information that needs to be provided is as follows:

• Last name of the individual
• First name(s) of the individual
• Date, place and country of birth
• Gender (male/female/unknown)
• Nationality (ies)
• Private address (usual place of residence)

It is important to note that the information provided will not be publicly disclosed, and nor will the LNIN be publicly available. The individual’s personal address is solely required for the purpose of creating the LNIN – the individual’s professional address can still be recorded in the RCS.

As part of the process, the RCS is modernising the system so that instead of the old PDF requisition form, the information will be filed directly online in HTML format.

The new system will bring significant administrative advantages, improving the consistency and quality of the information relating to the identification of natural persons collected by the RCS and the RBO (Register of Beneficial Owners).

For instance, the information relating to the surname and the first name(s) recorded in the RCS will be cross-checked with the national register of natural persons, and the Luxembourg address registered will be cross-checked with the “Registre national des localités et des rues”.

We advise businesses to put all natural persons registered with the RCS in compliance with this new requirement on a voluntary basis during the transitional period (whose exact duration has not been confirmed). After 12 November 2024, the registration of any new person in the RCS, or the modification of any details relating to someone already registered, will require a LNIN on a mandatory basis.

Our dedicated corporate secretarial team can provide assistance with any aspect of the new requirements including completing the filings on your behalf.

If you have any queries or would like to discuss anything relating to this matter, please don’t hesitate to get in touch.