Two facts explain almost everything founders experience at this step. First, banks in Luxembourg are not obliged to open a business account and may choose whether to take on an entrepreneur, but they are legally required to implement a customer acceptance policy.
Second, the published document checklist is a minimum prerequisite, with additional information or supporting documents requested depending on the circumstances and your risk profile. So the file you send is not a form to be completed. It is an argument made to a compliance desk that is free to decline, and that decides for itself how much more it wants to see.
The sections below follow the ABBL vademecum on opening a business account published on guichet.lu, which is a minimum standard developed by financial-sector experts, with the CSSF consulted during drafting, published by the ABBL in December 2024.
What a bank is and is not obliged to do
A bank need not take you on. What it must have is a customer acceptance policy, and that policy is what your file gets measured against.
The vademecum sets out risk factors that may include, but are not limited to, the customer's geographical origin or a particular link with certain countries, the products, services or transactions handled by the customer, the location of its customers, the origin of funds, the involvement of politically exposed persons, or the complexity of the legal structure chosen.
Those criteria are not uniform across the market: each bank may keep its own list of high-risk countries that goes beyond those officially recognised as high-risk under binding legal standards. Two banks can therefore reach opposite conclusions on the same company, and a refusal from one says more about that bank's risk appetite than about the business.
Before documents change hands, expect an onboarding questionnaire tailored to the proposed business relationship, which the bank uses to evaluate the risks of your project before deciding whether to establish a relationship at all. Answers that read as an ambition produce the email chains that slow every later step.
The KYC file, section by section
The seven sections below are the vademecum's own structure. Read the third column as the opening position. A higher-risk profile (an unusual jurisdiction in the ownership chain, a politically exposed person, a complex structure) adds documents to that column; it does not replace them.
| Vademecum section | What the bank must establish | Supporting documents |
|---|---|---|
| 01 Company identification | the full name and any trading name, legal form, country of incorporation, date of incorporation, registered office, trade register number and contact details | the articles of association or any equivalent constitutional document, plus a recent and up-to-date extract from the Trade Register |
| 02 Business and transactional profile | the countries and sectors of activity such as the NACE code, the size of the company's revenues, and the transactions and products expected to run through the bank in terms of volume, frequency and country | the company's latest financial statements, or, for a recently created company, revenue forecasts and a business plan |
| 03 Origin of funds | the operational origin of the funds, their geographical origin and their economic origin | a balance sheet, a sale or cash flow agreement, or a resolution deciding on a dividend distribution |
| 04 Beneficial owner | Whether any natural person owns or controls more than 25% of the company | a recent and up-to-date extract from the Register of Beneficial Owners, an Ultimate Beneficial Owner declaration form dated and signed by the company's representatives, and clear valid ID for each beneficial owner |
| 05 Shareholder information | Shareholders screened in the usual way against sanctions lists, politically exposed persons lists and adverse media | a recent organisational chart showing percentages of ownership and, where applicable, intermediate holding companies, plus a shareholder register requested depending on whether the ownership structure is already publicly available |
| 06 Management and authorised signatories | the full name of every director and senior managing official, and the full name, date and place of birth and legal address of residence of every authorised signatory and any other person who may act on behalf of the company towards the bank | the management structure, a list of authorised signatories with specimen signatures, the register of directors when applicable, clear and valid ID of each authorised signatory AND of any other person who can act for the company towards the bank, and, if relevant, a power of attorney for persons who can act on the company's behalf |
| 07 FATCA and CRS | Tax status for automatic exchange of information | a FATCA and CRS self-certification form, the company's tax identification number, the TIN of each controlling person for passive entities, and the US forms W9 or W8-BEN where required |
A founder who assembles exactly these documents and expects the account to follow has misread the exercise. The list is the floor.
Origin of funds is where files stall
Two terms get used interchangeably outside banks and mean different things inside one. Source of funds means the origin of the funds involved in a business relationship or occasional transaction, covering both the activity that generated them and the means by which they were transferred. Source of wealth means the origin of the customer's total wealth, for example inheritance or savings. A file that answers the second when the question was the first comes back.
A company being incorporated this month has no balance sheet and no dividend resolution, which is why this section is hard the first time. What stands in their place is the paper behind the shareholders' own money: a salary history, a sale agreement, a loan contract. That paper sits alongside the forecast already supplied under the business profile. "Personal savings" with nothing behind it does not answer a question about geographical and economic origin.
Who the bank means by a beneficial owner
More than 25% of the capital is the starting point, not the test. Under the law of 12 November 2004 on money laundering, a holding of 25% plus one share is only an indication of direct ownership, not a conclusive test.
Below the line the control limb still bites: a natural-person shareholder holding less than 25% of the capital is still a beneficial owner, and must be entered in the RBE, if they hold a preponderant voting right. There is a narrow fallback: where all possible means have been exhausted, there are no grounds for suspicion and no natural person can be identified, a natural person holding the position of senior managing official is identified as the beneficial owner.
Leaving the section open does not buy time. Where no beneficial owner can be identified, the bank cannot establish the business relationship, and for an existing relationship transactions should not be carried out and the relationship should be terminated.
A register extract does not close it either. The bank also takes a UBO declaration form, required by current CSSF regulation, and it supplements rather than replaces the extract from the Register of Beneficial Owners.
It is signed by the customer, meaning the company's legal representatives, and states for each identified beneficial owner the first name, surname, date and place of birth, nationality, legal address of residence, and whether that person is a politically exposed person. That last field is the one founders skip. Answered late, it reopens the file. The RBE filing itself is a separate obligation with its own deadline.
Opening the account while the company is still being incorporated
Opening before the company exists is possible, with the bank verifying the identity of the company's founders and the source of the funds used to constitute its capital. Where the form requires a notary, the sequence on guichet.lu's blocked-capital page runs like this:
- At the outset, the bank opens the account on the basis of the draft articles of association and it stays blocked for all transactions until the company is formed.
- Next comes a certificate the bank issues once the capital has been paid in, by which it undertakes to block the funds until the company is definitively formed.
- That certificate is handed by the entrepreneur to the notary, who then proceeds with the incorporation.
- A release certificate is issued by the notary to the entrepreneur once the company has actually been formed, after which the bank can unblock the capital and put it at the company's disposal.
- Alongside it the entrepreneur gives the bank the final articles of association, any missing supporting documents and information on the company's beneficial owners.
Minimum capital is €12,000 for a Sàrl and €30,000 for an SA; the Sàrl-S runs from €1 to €12,000. The paying-up rule then changed with the Law of 18 May 2026 amending the amended Law of 10 August 1915 on commercial companies, which introduced deferred paying-up of the minimum share capital of limited liability companies.
The deferral period is 12 months, and shares issued on incorporation in consideration for contributions in kind must still be fully paid up at incorporation — only cash contributions can be deferred.
None of that removes the identification work: the bank will not activate the account of a corporate client whose identification is incomplete, and may block it so that no funds are withdrawn until every required document has been provided.
And a bank that lets a corporate client access funds before identification is finalised may be held liable. That exposure is why chasing does not work: the bank carries the risk if funds move on an incomplete file, so the only thing that advances the review is the missing document.
How founders sabotage their own file
Four patterns send back a file that looked complete:
- Inconsistencies. Section 01 records the legal form, registered office and trade register number. If the address or the activity wording in the bank file differs from the permit application or the RCS filing, someone has to resolve that discrepancy in writing.
- Undocumented capital. Money with no trail cannot answer a question framed as operational, geographical and economic origin.
- Kitchen-sink activity descriptions. Section 02 asks for the sector, the NACE code and expected volumes, frequencies and countries. Listing every conceivable business line reads as evasive; describe year one.
- Impatience. Daily chasing does not accelerate a review that cannot conclude before the file is complete.
Common questions
Can a bank simply refuse?
Yes. The obligation is to operate a customer acceptance policy, not to accept every applicant. A refusal from one institution is not a refusal from the market: there is a list of dedicated contact persons that the ABBL maintains at abbl.lu/en/home/bank-account-opening to put project owners and bankers in touch.
Do I need an account before the company exists?
Where capital must be blocked, yes — the certificate goes to the notary before the deed. The deferred paying-up rule changes when the money must arrive, not whether the bank runs its checks.
Is an RBE extract enough for the bank?
No. The UBO form supplements the extract rather than replacing it, and it carries the politically-exposed-person question the register does not.
What to prepare before approaching a bank
Work in the vademecum's order and the file assembles itself: constitutional documents and register extract, business profile with NACE code and expected flows, origin-of-funds paper per contributing shareholder, UBO pack, ownership chart, signatory list, FATCA and CRS self-certification.
Then put the permit application and the draft statutes beside it and make every name, address and activity description identical. There is also a monthly online workshop on the basics of tax and accounting obligations and opening bank accounts, offered by the House of Entrepreneurship to all future entrepreneurs and company directors.