1) Registration of beneficial owners
Entities that have to register their beneficial owner(s) with the RBE are those registered with the RCS, with the sole exception of merchants who are natural persons.
To complete this procedure, the entity has to declare the beneficial owners to the RBE using the Beneficial owners procedure and then selecting the service Declaration of beneficial owners.
In order to be able to declare beneficial owners, the user must have authenticated themselves using a LuxTrust electronic certificate, via the GouvID application or an eIDAS certificate.
After selecting this service, the user moves on to the next page where they must check the box relating to the Declaration of honour in order to certify that they are duly mandated to make the declaration.
Without this action, it is impossible for the user to continue with the procedure for declaring beneficial owners.
Once the Declaration of honour box has been checked, the user is asked to select the language of the data entry form for the declaration request.
The user validates the creation of their declaration request by clicking on the Register button corresponding to the category of beneficial owners they wish to declare.
It is the responsibility of the registered entity to carry out the necessary research in advance to identify its beneficial owner(s) (Pdf, 532 Kb), who must be natural persons.
Three categories of beneficial owners are proposed:
- Senior managing officials when the beneficial owners cannot be identified.
- Beneficial owners when they can be identified.
- Stock exchange listing (if applicable) provided that the entity is listed on a stock exchange.
Only one type of beneficial owner can be declared. The user is then redirected to the data entry form corresponding to the selected service.
Important: Make sure you have all the information required for registration and any documentary evidence (if applicable).
Declaration of beneficial owners
Data entry form: Things to know
Senior managing officials
In the section entitled Saisie des données à inscrire (Data to be entered), the user is first asked to answer the question regarding the possession of a Luxembourg national identification number by selecting one of the following options:
- Yes, if the person to be declared has a Luxembourg national identification number.
- No, if the person to be declared does not have a Luxembourg national identification number.
The user also has the option of adding a senior managing official by clicking on the link Ajouter un dirigeant prinicpal (Add senior managing official).
By selecting Yes, the user displays the various sub-sections and corresponding input fields. They are then asked to enter the required data in order to continue with their declaration. When all the fields have been completed, the user has to click on the button Vérifier la saisie (Verify entry). This action triggers a verification of the data entered. Any errors or missing data are highlighted in red in the form. The user is then asked to correct them before continuing.
After validating the entry, the user can proceed to the next step by clicking on the section Vérification de ma demande (Verification of my application). If the senior managing official has a Luxembourg national identification number, no documentary evidence is required to complete the declaration.
By selecting No, the user displays the various sub-sections and corresponding input fields. They are then asked to enter the required data in order to continue with their declaration. When all the fields have been completed, the user has to click on the button Vérifier la saisie (Verify entry). This action triggers a verification of the data entered. Any errors or missing data are highlighted in red in the form. The user is then asked to correct them before continuing.
After validating the entry, the user proceeds to the next step by clicking on the section Pièce(s) à joindre à la déclaration (Documents to be attached to the declaration).
In the section Pièce(s) à joindre à la déclaration (Documents to be attached to the declaration), the user must attach the required documentary evidence in the field Pièces justificatives (Documentary evidence) by clicking on the button Ajouter la pièce jointe (Add attachment). The list of documents to be attached is provided based on the information entered in the section Saisie des données à inscrire (Enter data to be registered). To continue with the declaration, the user must then click on the link Aller à la mise au panier (Go to cart).
The Vérification de ma demande (Verification of my application) section contains a summary of the request for verification purposes by the user before it is placed in the cart.
The user is invited to view the summary of their declaration in PDF format by clicking on the link Visualiser le récapitulatif de ma demande en français (View a summary of my request in French). In the event of an error found when verifying the summary document, the user can return to the request by clicking on the previous step until reaching the section or sub-section for which the information needs to be corrected.
If, at this stage of reviewing the summary document, the user confirms that the information entered is correct, they must check the box J’ai contrôlé mon document récapitulatif (I have verified my summary document).
The user can also indicate a declaration reference in the Ma référence de déclaration (My declaration reference) field, which can be defined freely, to better organize their requests. The user then validates their declaration by clicking on the Ajouter la demande au panier (Add request to cart) button.
Beneficial owners
In the section entitled Saisie des données à inscrire (Data to be entered), the user is first asked to answer the question regarding the possession of a Luxembourg national identification number by selecting one of the following options:
- Yes, if the person to be declared has a Luxembourg national identification number.
- No, if the person to be declared does not have a Luxembourg national identification number.
The user also has the option of adding a beneficial owner by clicking on the link Ajouter un bénéficiaire effectif (Add beneficial owner).
By selecting Yes, the user displays the various sub-sections and corresponding input fields. They are then asked to enter the required data in order to continue with their declaration. When all the fields have been completed, the user has to click on the button Vérifier la saisie (Verify entry). This action triggers a verification of the data entered. Any errors or missing data are highlighted in red in the form. The user is then asked to correct them before continuing.
After validating the entry, the user can proceed to the next step by clicking on the section Vérification de ma demande (Verification of my application). If the beneficial owner has a Luxembourg national identification number, no documentary evidence is required to complete the declaration.
By selecting No, the user displays the various sub-sections and corresponding input fields. They are then asked to enter the required data in order to continue with their declaration. When all the fields have been completed, the user has to click on the button Vérifier la saisie (Verify entry). This action triggers a verification of the data entered. Any errors or missing data are highlighted in red in the form. The user is then asked to correct them before continuing.
After validating the entry, the user proceeds to the next step by clicking on the section Pièce(s) à joindre à la déclaration (Documents to be attached to the declaration).
In the section Pièce(s) à joindre à la déclaration (Documents to be attached to the declaration), the user must attach the required documentary evidence in the field Pièces justificatives (Documentary evidence) by clicking on the button Ajouter la pièce jointe (Add attachment). The list of documents to be attached is provided based on the information entered in the section Saisie des données à inscrire (Enter data to be registered). To continue with the declaration, the user must then click on the link Aller à la mise au panier (Go to cart).
The Vérification de ma demande (Verification of my application) section contains a summary of the request for verification purposes by the user before it is placed in the cart.
The user is invited to view the summary of their declaration in PDF format by clicking on the link Visualiser le récapitulatif de ma demande en français (View a summary of my request in French). In the event of an error found when verifying the summary document, the user can return to the request by clicking on the previous step until reaching the section or sub-section for which the information needs to be corrected.
If, at this stage of reviewing the summary document, the user confirms that the information entered is correct, they must check the box J’ai contrôlé mon document récapitulatif (I have verified my summary document).
The user can also indicate a declaration reference in the Ma référence de déclaration (My declaration reference) field, which can be defined freely, to better organize their requests. The user then validates their declaration by clicking on the Ajouter la demande au panier (Add request to cart) button.
Stock exchange listing
In the section entitled Saisie des données à inscrire (Data to be entered), the user is asked to fill in the following fields:
- Système de cotation (Rating system)
- Pays de cotation (Country of rating)
When all the fields have been completed, the user has to click on the button Vérifier la saisie (Verify entry). This action triggers a verification of the data entered. Any errors or missing data are highlighted in red in the form. The user is then asked to correct them before continuing.
After validating the entry, the user proceeds to the next step by clicking on the section Pièce(s) à joindre à la déclaration (Documents to be attached to the declaration).
In the section Pièce(s) à joindre à la déclaration (Documents to be attached to the declaration), the user must attach the required certificate in the field Pièces justificatives (Documentary evidence) by clicking on the button Ajouter la pièce jointe (Add attachment). To continue with the declaration, the user must then click on the link Aller à la mise au panier (Go to cart).
The Vérification de ma demande (Verification of my application) section contains a summary of the request for verification purposes by the user before it is placed in the cart.
The user is invited to view the summary of their declaration in PDF format by clicking on the link Visualiser le récapitulatif de ma demande en français (View a summary of my request in French). In the event of an error found when verifying the summary document, the user can return to the request by clicking on the previous step until reaching the section or sub-section for which the information needs to be corrected.
If, at this stage of reviewing the summary document, the user confirms that the information entered is correct, they must check the box J’ai contrôlé mon document récapitulatif (I have verified my summary document).
The user can also indicate a declaration reference in the Ma référence de déclaration (My declaration reference) field, which can be defined freely, to better organize their requests. The user then validates their declaration by clicking on the Ajouter la demande au panier (Add request to cart) button.
Data entry form: information to be registered with the RBE
Beneficial owners or senior managing officials
How to complete the field relating to the Luxembourg national identification number?
The Luxembourg national identification number must be registered with the RBE for beneficial owners / senior managing officials who have such a number. In this case, no documentary evidence needs to be provided.
How to complete the field relating to the foreign identification number?
The foreign identification number to be entered must correspond to the one appearing on the documentary evidence to be attached to the declaration.
Specific case 1: the beneficial owner / senior managing official has a foreign national identification number
- If a national identification number exists in the country, this number must be indicated on the declaration. It must also appear on the documentary evidence to be attached to the declaration. It should be noted that in this case, as long as the foreign national identification number has been entered in the declaration, there is no need to indicate the number of the identity document in the RBE declaration.
Specific case 2: the beneficial owner / senior managing official has an identity document number (in the absence of a national identification number)
- If there is no unique national identification number, the number to be given in the declaration to the RBE is the number of the identity document presented (e.g. passport number). Only this number will be accepted; any other number, even if it appears on the document presented, will be refused.
Likewise, when a document has different national identification numbers (e.g. tax identification number and national insurance number), the number of the identity document presented must be indicated. The document numbers accepted are those on the identity documents accepted as proof of the person's identity (Identity card - Passport - Residence/resident permit - Driving licence).
Important: In accordance with the update of Luxembourg national identification numbers assigned to natural persons registered with the RCS, reporting entities are required to ensure that the data declared is consistent. Where necessary, they are responsible for updating the foreign identification number previously provided without delay, in accordance with the regulatory provisions in force.
How to complete the fields relating to surname and first name(s)?
- For beneficial owners or senior managing officials with a Luxembourg national identification number, the information relating to the surname and first name(s) to be included on the form must correspond exactly to the information in the National Register of Natural Persons.
- For beneficial owners or senior managing officials who do not have a Luxembourg national identification number, the information to be provided must be consistent with the documentary evidence to be attached, enabling the identity of the person to be established. If the person has more than one first name, all of them must be indicated on the form. As regards the field relating to the name, the information should be entered as it appears on the official documentary evidence. Please note that characters such as quotation marks, commas or parentheses are not to be entered in these fields.
For further information, consult our FAQ - Luxembourg national identification number.
How to complete the field relating to nationality?
The nationality of the beneficial owner / senior managing official to be registered must be selected from a drop-down list on the form. If the person has multiple nationalities, all of them must be registered with the RBE. To do this, the user is asked to click on the Ajouter une nouvelle nationalité (Add a new nationality) option and select it from the drop-down list.
If the person has a Luxembourg national identification number, the information to be communicated to the RBE must be in accordance with the entries in the National Register of Natural Persons.
How to complete the fields relating to date and place of birth?
The date of birth (day, month and year) and place of birth (town and country) must be registered with the RBE and must be consistent with:
- The information contained in the National Registry of Natural Persons, if the person has a Luxembourg national identification number.
- The information contained in the attached documentary evidence, for persons who do not have a Luxembourg national identification number.
Please note that if the person to be registered has a Luxembourg national identification number, the date of birth will be automatically generated in the field provided for this purpose.
How to complete the field relating to country of residence?
The country of residence of the beneficial owner / senior managing official to be registered must be selected from a drop-down list provided on the form.
How to enter the exact address, private or professional?
The professional address or private address of the beneficial owner / senior managing official is to be entered. The full address must be provided. The street name must be written in full, i.e. including terms such as street, avenue, boulevard, etc.
Please note that for Luxembourg addresses, the information provided to the RBE concerning the locality, street and building number must be consistent with the data in the national register of localities and streets. An automatic address check is carried out directly on the declaration form to be completed by the applicant. The National Register of Localities and Streets can be consulted here. No documentary evidence of the address needs to be attached.
How to enter the nature and extent of the effective interests held?
The fields relating to the nature and extent of beneficial interests held are only provided if the beneficial owners who are natural persons have been identified. If senior managing officials are to be registered, these fields are not provided on the declaration form.
- Nature des intérêts effectifs (Nature of beneficial interests): The information to be entered in this field concerns only the nature of the interests held. These may include, for example, shares, equity interests, capital interests or voting rights.
- Étendue (Scope): The information to be disclosed specifically refers to the precise scope of the effective interests held. It is not sufficient to indicate "strictly greater than 25%". This may, for example, be a percentage or a proportion.
If an effective interest type needs to be added, the user is prompted to click on the Ajouter un type d’intérêt effectif (Add an effective interest type) option to open the fields for completion.
Concerning the fields relating to the restriction of access to consultation (only for beneficial owners)
These fields are only accessible if beneficial owners have been identified. If the option to restrict access to consultation is selected, the sections Motif(s) (Reason(s)) and Durée du risque (en mois) (Duration of risk (in months)) – limited to 36 months – appear on the page. The request to restrict access has to be sent to the LBR administrator at the same time as the declaration of beneficial owners.
The user must check the risk(s) incurred by the beneficial owner concerned, attach documentary evidence justifying the request, and indicate the preferred duration of the restriction (in months).
Concerning the field relating to the function (only for certain senior managing officials)
In principle, this field should not be completed. It is provided to enable certain senior managing officials to specify the particular nature of their function. This is the case for legal representatives (e.g. provisional board members) or liquidators. When this field is completed in the form, a systematic consistency check is carried out against the data entered in the RCS. The function entered in the RBE must correspond to that entered in the RCS.
Concerning stock exchange listing
When the registered person is a listed company, it only has to register with the RBE the name of the regulated market on which its securities are admitted to trading, as well as the country. Documentary evidence must be provided when registering with the RBE. This exemption applies only in this specific case and not where the listed company is an associate of the registered company and not the registered company itself.