LBR’s New Enforcement Phase – What You Need to Know
On 8 September 2026, Luxembourg Business Registers (“LBR”) published a public notice announcing the launch of the enforcement phase of its monitoring and compliance procedure for data registered with the Trade and Company Register (“RCS”) and the Beneficial Owners Register (“RBE”). The enforcement phase will take effect on 21 September 2026.
- Published
- in Analysis & Insights
This phase is implemented under the Law of 23 January 2025, which significantly strengthens LBR’s responsibilities for monitoring and ensuring the compliance of registered data. The overarching objective is to improve the quality, reliability and integrity of register data, so that public authorities, economic operators and all users can access accurate, up-to-date and readily usable information on entities registered in Luxembourg.
Background: The Prevention Phase
Prior to the enforcement phase, LBR dedicated nearly seven months to prevention, information and support measures. These included broad information campaigns, the sending of personalised letters to entities concerned and the publication of a detailed compliance guide. Instances of non-compliance have also been flagged directly on the LBR portal during filing procedures, enabling applicants to identify and address issues proactively.
Scope of the enforcement phase
The enforcement phase applies to entities whose RCS or RBE file contains one or more instances of non-compliance. These may include: incorrect, outdated, inconsistent or missing information, or failure to complete a mandatory procedure.
Notably, non-profit associations (ASBLs) and foundations are not subject to the opening of enforcement proceedings at this stage, as awareness-raising and information measures are still ongoing for these entities.
Enforcement proceedings and progressive measures
From 21 September 2026, LBR will open new enforcement proceedings progressively, on a daily basis over a period of several weeks. Thereafter, new proceedings will be opened as new instances of non-compliance are detected, to ensure continuous monitoring of the compliance of registered files.
Each enforcement proceeding begins with the sending of a registered letter informing the entity of the instances of non-compliance detected in its file and inviting it to take the necessary steps to regularise them. The date on which this letter is sent (the “T date”) marks the starting point of the proceeding.
If the instances of non-compliance are not regularised within one month of the T date, the following measures will be implemented progressively and will apply cumulatively:
| Deadline | Measure |
| T + 30 days | Display of a warning. A warning is displayed on the LBR portal when the file of the entity concerned is consulted publicly. |
| T + 60 days | Reference on extracts and certificates. Instances of non-compliance that have not been regularised are indicated on extracts and certificates issued by LBR, in addition to the warning already displayed. |
| T + 7 months | Imposition of a penalty payment. A daily penalty payment of €40 is imposed for a maximum period of 90 days, up to a maximum amount of €3,600. |
| T + 12 months | Deletion ex officio. LBR proceeds with the deletion ex officio of the entity from the register. This deletion results neither in the dissolution of the entity nor in the loss of its legal personality. |
| After deletion ex officio | Possible further actions. The file may be referred to the State Prosecutor. If the legal requirements are met, the entity may also be subject to a proceeding for administrative dissolution without liquidation (“PDAL”). |
Regularisation
Entities may regularise their file at any stage of the enforcement proceeding. The regularisation of all instances of non-compliance will bring the proceeding to an end and result in the lifting of the measures applied, in accordance with the applicable legal provisions and without prejudice to any financial consequences arising from measures already implemented.
Conclusion
The launch of the enforcement phase represents a significant step in Luxembourg’s efforts to strengthen the transparency, reliability and legal certainty of its business registers. Entities that have not yet addressed outstanding instances of non-compliance in their RCS or RBE files are encouraged to act promptly to avoid the progressive application of the measures outlined above.
A compliance guide outlining the different types of instances of non-compliance, the steps required to regularise them and other relevant information is available on the LBR portal at www.lbr.lu.
For further information, please reach out to your usual Maples Group contact or any of the persons listed on this page.
