RBE Luxembourg: Register of Beneficial Owners

Who is a beneficial owner?

A beneficial owner is any natural person who directly or indirectly holds more than 25% of the capital or voting rights of the entity, or who exercises control by other means (shareholders' agreement, right to appoint/remove the majority of directors). If no natural person can be identified under these criteria, the effective directors (managers, board members) must be declared as beneficial owners "by default". For cascade structures, the ownership chain must be traced up to the ultimate natural persons.

Information to be declared

• Name, first names, date and place of birth, nationality/nationalities
• Country of residence and private address
• Nature and extent of the effective interest held (ownership percentage)
• Date on which the person became a beneficial owner
• National identification number (if available)

Update obligations and penalties

Any change to the beneficial owners must be declared to the RBE within a one-month deadline. The accuracy of the information must be confirmed annually. Penalties for non-declaration, late declaration or inaccurate declaration range from €1,250 to €1,250,000 in fines. The legal representative of the entity (manager, director) is personally liable for compliance. Since the 2022 CJEU ruling, public access to the RBE has been restricted: only competent authorities, AML-regulated entities and persons demonstrating a legitimate interest have access.