Based on the provisions of the RBO Law1, all in-scope Luxembourg
entities were required to comply with the provisions of the RBO Law
and, in particular, file information on their beneficial owner(s)
with the register of beneficial owners
("RBO") by the end of August 2019.
On 2 September 2019, the Luxembourg Business Registers
("LBR") announced the postponement of
the administrative deadline for entities to file the relevant
information on their beneficial owners with the RBO. Entities now
have until 30 November 2019 to file the relevant information and
the registrations made in the RBO until that date remain free of
charge.
As indicated in our
Newsflash dated 2 September 2019, this extension is purely an
administrative decision, which cannot in principle override the
deadline of 31 August 2019 set by the RBO Law. Therefore, existing
entities which only file within the extended deadline (30 November
2019) will not, strictly speaking, comply with the RBO
