The RCS no longer displays the date and place of birth of registered natural persons such as managers and partners — and for natural-person traders also nationality, private address and marital details. Your annual accounts are still filed publicly, and only a small company may file the abridged version.
The company register now shows fewer personal fields
The change reaches new filings before older records. That means a third party reading the register today can meet two versions of the same company: an older entry that still carries the fields filed at that date, and a newer entry from which the date and place of birth have already been removed.
The LBR's announcement describes the data-minimisation rule as removing the date and place of birth of registered natural persons such as managers and partners from the RCS display; for natural-person traders, the same rule also drops nationality, private address and marital details.
That distinction matters: a manager or partner loses date and place of birth, while a natural-person trader loses a wider set of personal fields. The register remains public; it just exposes fewer personal markers.
This does not close the register. The company record itself stays public, and anyone can still order an extract.
A public extract remains available for a fixed fee
Public access to the RCS is now a question of what the extract still shows, because the extract remains available to anyone. The fee regulation sets the plain electronic extract at €10.43 excluding VAT, the qualified-signature electronic extract at €15.43 excluding VAT, and the paper extract at €21.43 excluding VAT. The electronic route is the cheapest of the three, and the personal-data content is now smaller.
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The beneficial-owner register is the stricter side
Public access to the RBE is not open. The LBR help page records that public access to the RBE was suspended following a Court of Justice of the European Union judgment. The law still opens the register to limited access categories, including people who demonstrate a legitimate interest in the fight against money laundering and terrorist financing (consolidated RBE law). The RBE is therefore the opposite of the RCS on this point: the RCS sells extracts to anyone, while the RBE is conditional.
Access that does exist leaves a trace. Under the consultation-traceability rule, consulting an entity's RBE file or ordering an RBE extract requires stating a reason for each consultation, recorded under the amended RBE law — the LBR reports. In other words, the RBE is a restricted and logged register, not a public search box.
What the RBE collects is broader than what it shows
The data the law requires is deeper than what most readers will ever see. The consolidated law lists the required details for each beneficial owner: surname, first name or names, nationality or nationalities, day, month and year of birth, place of birth, country of residence, exact private or business address, Luxembourg national identification number or a foreign identification number, and the nature and extent of the beneficial interests held.
But the LBR help page states that the address and the identification number of the registered beneficial owners stay hidden, as do the details of any owner whose access-restriction request has been granted or is still being assessed. An access restriction lasts up to 3 years, and the register keeps the data for 5 years. Filing an RBE declaration costs €15 excluding VAT, on the same help page. The register therefore collects fields that the same professional audience is not shown.
The annual accounts remain open
Annual accounts are filed at the RCS and stay public. The filing deadline has two legs: the accounts are approved first, and the company files them within 1 month of that approval. The outer deadline is 7 months after the financial year-end, as the guichet page on the deposit of annual accounts states. That is the outer deadline, not a suggestion tied to opening contact with the administration. A founder who reads only the outer date misses that the approval must already have happened.
There is a filer-level carve-out. A natural-person trader whose turnover does not exceed €100,000 is outside the annual-account filing obligation, according to the same source. That carve-out is limited to natural-person traders; it does not change the position of a Sàrl or an SA.
The abridged filing depends on a size test
The abridged filing is not available to every company. It follows the small-company size test, and the current thresholds are a balance-sheet total of €7,500,000, net turnover of €15,000,000, and 50 employees (consolidated company law). Those are the limits for financial years beginning on or after 1 January 2023, as the regulation sets out. A company that remains small under those limits may file the abridged version.
Size does not change on a single year
Size does not move on a single year. The rule is that crossing the limits of two of the three criteria only changes a company's size class if it happens at two consecutive balance-sheet dates.
The audit exemption follows the same limits
Staying within the small-company limits has a further effect. Small companies are exempt from appointing a réviseur d'entreprises agréé; the audit is triggered by exceeding the limits under the same size test (consolidated company law). The filing exemption and the audit exemption therefore ride on the same classification. Exceeding two of the three limits in a single year is not enough on its own; the same two-limit condition is what triggers the audit.
The next class up comes with its own thresholds
Above the small class, the next size class starts at a balance-sheet total of €25,000,000, net turnover of €50,000,000, and 250 employees. The regulation also carries the superseded figures for both classes: for the small class, a balance-sheet total of €4,400,000 and net turnover of €8,800,000; for the medium class, a balance-sheet total of €20,000,000 and net turnover of €40,000,000.
The registers are separate privacy lines, not a single setting
Treat the RCS, the RBE and the filed accounts as separate lines. The table is the short form, and the same founder can appear in all three rows.
| Register or filing | Public access | Fields the public can no longer see | What remains visible |
|---|---|---|---|
| RCS | Extract available to any applicant for a fee | Date and place of birth of managers and partners; for natural-person traders also nationality, private address and marital details | The company's register entry, less those personal fields |
| RBE | No public access; limited categories only | Address and identification number of the beneficial owner; details of a person with a granted or pending access-restriction request | The fields the law opens to the limited access category |
| Annual accounts | Filed publicly | — | The filed accounts; abridged only where the small-company test is met |
The RCS still sells extracts and shows less personal data; the RBE is restricted and logged; the annual accounts remain publicly filed, and only a small company may shorten them. An address can be hidden in a specific register and collected in a different register, and the same company can have a thin RCS file and a public set of accounts.
For a founder still choosing the structure, which of these records exists and who appears in them is fixed early; the company formation works that out at the start.
See what company formation includes, from €899Figures verified against lbr.lu, lbrcontent.public.lu, cssf.lu, legilux.public.lu, legilux.public.lu, guichet.public.lu, data.legilux.public.lu on 2026-10-30.