The Luxembourg Business Registers ("LBR") announced yesterday that the administrative deadline regarding the Registre des bénéficiaires effectifs ("RBO") filing has been extended until 30 November 2019.
Although this does not technically prevent the Luxembourg repressive authorities from sanctioning any entity which does not comply with its obligations by the 31st August 2019 deadline (which remains the official deadline in the Luxembourg law of 13 January 2019 introducing a central register of beneficial owners ("BOs") of Luxembourg entities (the “RBO Law”)), we understand that the authorities have been informed of this administrative extension, and thus that entities now should in principle have some additional time to comply with the RBO Law.
As a reminder, pursuant to the RBO Law, Luxembourg entities are required to obtain and hold adequate, accurate and up-to-date information on their BOs at their registered office (the so called “Internal File”). Such information must in addition be uploaded into a newly created RBO maintained by the LBR.
As a result of the above, and despite the extension of the administrative deadline, we would still suggest complying with the RBO as soon as possible.