The Luxembourg Business Registers (LBR) announced that the administrative deadline for entities to file the relevant information pertaining to their beneficial owners with the Register of Beneficial Owners (“RBO”) has been postponed to 30 November 2019. Registrations made until that date will remain free of charge.
However, it should be noted that this extension is purely an administrative decision which cannot, in principle, override the deadline of 31st August 2019 as set out by law (of 13 January 2019) (the “RBO Law”). As such, entities which file after 31 August but within the extended deadline of 30 November 2019 will not comply, strictly speaking, with the RBO Law. That being said, given the official administrative extension announced by the LBR, one hopes that one can 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.