The register of beneficial owners, made clear.
Every Luxembourg company must tell the RBE who really owns or controls it. Who counts, what to file, the one-month deadline, who can see it since 2025, and what happens if you don't. Every rule is linked to the law.
| Holds directly in your company, % | Holds in the holding company, % | |
|---|---|---|
| Anna | ||
| Ben | ||
| Chloé |
Nobody passes the test: the managers are registered as senior managing officials, unless someone controls the company in another way.
of the shares, voting rights or capital, held directly or indirectly, makes a person a beneficial owner. So does controlling the company by other means.
Who is a beneficial owner?
A beneficial owner is always a natural person: the individual who ultimately owns or controls the company, even through other companies. A holding company is never the answer; the people behind it are.
If no one meets the test after every means has been exhausted, and nothing is suspicious, the company registers its senior managing officials instead.
Companies whose shares are listed on a regulated market only record the name and country of that market.
Sources: LBR, guide to defining beneficial owners · Law of 13 January 2019 on the RBE, coordinated text
Three checks, in this order.
The method the Luxembourg Business Registers recommend.
- Step 1
Count the ownership
Work out each person's share of the capital, directly and through other companies. Along a chain, multiply the percentages. More than 25% makes a beneficial owner.
- Step 2
Look for control
Check who controls the company in another way: more than 50% of the votes somewhere in the chain, a shareholder agreement, or other means of control. Run this check together with the first one.
- Step 3
Fall back on the managers
If nobody is found after exhausting all means, and nothing is suspicious, register the senior managing officials: the managers or the board.
The person's indirect share is only 18% (60% of 30%). But with 60% of the holding, they control its 30% stake, which is above 25%. They are a beneficial owner.
What to file, and when.
Every company, association, foundation and other entity registered with the RCS, sole traders excepted, declares its beneficial owners to the RBE, run by the Luxembourg Business Registers.
For each beneficial owner
- Name and first names
- Nationalities
- Date and place of birth
- Country of residence
- Private or professional address
- National identification number
- Nature of the beneficial interest
- Extent of the beneficial interest
Deadlines and fees
The month runs from the day the company learned, or should have learned, of the change. Late filings cost €50 to €500 extra. The company must also keep the information and its supporting documents at its registered office, and each beneficial owner must give the company what it needs.
Sources: Law of 13 January 2019 on the RBE, coordinated text · LBR, RBE fee schedule
No longer public.
Since 1 February 2025, access is limited to specific groups, each within its own limits.
When the register is wrong.
If the LBR asks a company to check or correct its entries and nothing happens within 30 days, the measures build up month by month after the request.
- Month 2A notice on the LBR website
- Month 3Certificates listing the breaches
- Months 7 to 9A penalty of €40 a day
- Month 12Administrative removal from the register
Source: Law of 23 January 2025 (RBE and RCS)
Criminal fine for a company that knowingly fails to file in time, or files inaccurate, incomplete or outdated information.
Sources: Law of 13 January 2019 on the RBE, coordinated text · Law of 23 January 2025 (RBE and RCS)
The same range for not keeping the information at the registered office, and for a beneficial owner who doesn't give the company what it needs.
The RBE, answered.
What company owners ask us most about their beneficial owners.
Book a free first callThe Register of Beneficial Owners, kept by the Luxembourg Business Registers. Every company and other entity registered with the RCS, except sole traders, declares there the natural persons who ultimately own or control it.
A natural person who owns or controls more than 25% of the shares, voting rights or capital, directly or indirectly, or who controls the company by other means. If nobody qualifies, the senior managing officials are registered.
One month from the day the company learned, or should have learned, of the event: its creation, or any change in its beneficial owners.
The LBR charges €15 excluding VAT for a registration, with €50 to €500 extra for late filings. Finbros prepares and files the declaration for €100.
Sources: LBR, RBE fee schedule · Finbros services and rates
No longer. Since 1 February 2025, access is limited to national authorities, professionals with anti-money laundering duties, and people who show a legitimate interest to the LBR.
If it doesn't respond to the LBR within 30 days, the LBR can publish a notice, issue certificates listing the breaches, charge €40 a day from the 7th to the 9th month and remove the company from the register from the 12th month. Criminal fines of €1,250 to €1,250,000 also apply.
Sources: Law of 23 January 2025 (RBE and RCS) · Law of 13 January 2019 on the RBE, coordinated text
First check whether someone controls the company another way, for example through a shareholder agreement. If nobody does, the managers or board members are registered as senior managing officials.
In exceptional cases, such as a disproportionate risk of fraud or kidnapping, or a beneficial owner who is a minor, the company or the beneficial owner can ask the LBR to limit access.
Sources: Law of 13 January 2019 on the RBE, coordinated text · LBR, guide to defining beneficial owners
Get your RBE filing right.
We work out your beneficial owners, file the declaration and keep it up to date when things change. Book a free first call, Saturdays included.
Rules and fees as they apply in November 2026. General information, not legal advice for your situation. Part of the Finbros Encyclopedia.