Luxembourg's upcoming deadlines for filing LNIN

Stricter filing requirements for Luxembourg national identity numbers are coming into force, including a new filing fee effective from 1 June 2025 and a compliance deadline of 1 October 2025.

To prevent any disruptions in your entity’s administration and operations, it is strongly advised to verify whether all individuals concerned already have a Luxembourg national identity number (LNIN) or need to request one, and to complete all necessary actions for the relevant LNIN filings.

Background to LNIN filings

Since 12 November 2024, all filings with the Luxembourg Trade and Companies Register (RCS) must include an LNIN for all natural persons registered or to be registered with the RCS in any capacity (shareholders, directors, managers, day-to-day manager, and auditors, etc). 

The LNIN is a unique identification number assigned by the National Register of Natural Persons (Registre National des Personnes Physiques). For natural persons affiliated with the Luxembourg social security system, the LNIN corresponds to the commonly known “Matricule” or “CNS” number. For those who do not yet have an LNIN, it will be necessary to request one. 

Applicants who do not have an LNIN are required to provide details including last name, first names, date and place of birth, nationality, gender and private residence. Supporting documents for identity verification and proof of residence must also be included with the application. 

Once filed, the LNIN will not be publicly available on the RCS.

Requesting or updating an LNIN of a natural person is currently free of charge. However, on 3 March 2025, the Luxembourg Business Registers (LBR) published a notice announcing that stricter filing requirements regarding the LNIN will be enforced soon.

Read more about the RCS requirements for LNIN. 

What happens at the end of May?

• The last business day to update the LNINs free of charge is 31 May 2025.

• Effective from 1 June 2025, the RCS will charge a fee for any LNIN filing (€10.95 per filing).

Deadline for updating an LNIN

The LBR has set an official deadline for compliance. Effective 1 October 2025, failure to update an individual’s LNIN with the RCS may result in the suspension of any kind of filing procedures (such as share capital updates, merger proposals, submission of annual accounts and change of registered office address / board composition etc) until the missing LNIN is provided.

Actions to be taken

Ahead of these deadlines, entities are advised to verify whether all concerned individuals already have an LNIN or need to request one, and to complete all necessary actions for the LNIN filings.

How Ogier can help

If you have any questions or need assistance with obtaining or updating an LNIN or submitting it to the RCS, Ogier's Corporate law experts in Luxembourg can assist. Please contact your usual representative. 

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice