The Luxembourg Business Registers (LBR) announced that the administrative deadline for entities to file the relevant information on their beneficial owners with the Register of Beneficial Owners (“RBO”) is postponed to 30 November 2019. Registrations made until that date will remain free of charge.
This extension is purely an administrative decision which cannot, in principle, override the deadline of 31st August 2019 set by the law of 13 January 2019 creating a Register of Beneficial Owners (the “RBO Law”). We refer to our Newsflash on the RBO Law and related publications on our website. Accordingly, existing entities which only file within the extended deadline until 30 November 2019 will not comply, strictly speaking, with the RBO Law. However, given the official administrative extension announced by the LBR, it is reasonable to assume that there will be no adverse consequences for the relevant entities or their beneficial owners, in particular in respect of potential criminal law sanctions set out in the RBO Law.