RBE compliance checks in Luxembourg
The Luxembourg Public Prosecutors of Luxembourg and Diekirch have announced the launch of systematic controls relating to compliance with the Luxembourg Register of Beneficial Owners (Registre des bénéficiaires effectifs – “RBE”).
According to the official press release published on 4 May 2026, checks will be carried out in the coming weeks across all the country.
This announcement confirms the increasing focus of Luxembourg authorities on beneficial ownership transparency and AML/CFT compliance. It also follows recent legislative reforms aimed at strengthening the quality, reliability and monitoring of information filed with the Luxembourg Business Registers (“LBR”).
Under the Luxembourg law of 13 January 2019, establishing the RBE, as amended, Luxembourg entities falling within the scope of the legislation must identify their beneficial owners, maintain adequate and accurate supporting information and ensure that the relevant data filed with the RBE remains complete, accurate and up to date.
In practice, a beneficial owner generally refers to the natural person(s) ultimately owning or controlling the relevant entity, notably through direct or indirect ownership of more than 25% of the share capital or voting rights, or through other means of control.
The recent communiqué specifically reminds market participants that breaches of the RBE legislation may trigger significant criminal sanctions, including fines ranging from 1,250 euros to 1,250,000 euros. In addition, entities that cannot be located at their registered office or address may face dissolution proceedings without liquidation or judicial liquidation.
The authorities’ communication should therefore be viewed as a clear warning to Luxembourg companies, partnerships, funds, SPVs, associations and other registered entities that RBE compliance is no longer considered a mere administrative formality.
Particular attention should notably be paid to:
- the identification of the ultimate beneficial owner(s);
- the consistency between the RBE, the RCS and the entity’s corporate documentation;
- the accuracy of shareholding and control information;
- the update of any changes affecting beneficial ownership; and
- the effective presence of the entity at its registered office.
Given the announced controls and the reinforcement of the LBR supervisory powers, Luxembourg entities would be well advised to conduct an internal review of their current RBE filings and supporting documentation without delay.
Our team remains at your disposal should you have any questions in this regard or require any assistance. Please visit our website for further information.
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