Luxembourg Clarifies Beneficial Ownership Reporting Rules for Trusts

Luxembourg Business Registers (LBR) has clarified how companies held through trusts, fiducies or foundations must identify and report beneficial owners to the country’s Register of Beneficial Owners (RBO). Circular LBR 26-01, published on 19 August 2026, confirms that reporting entities should look through the legal arrangement and register the natural persons who are beneficial owners of the underlying trust, fiducie or foundation, rather than relying only on the general company ownership test.

The guidance addresses uncertainty where a company is owned through a trust structure, including arrangements established outside Luxembourg. Under the clarified approach, reportable beneficial owners include settlors, trustees or fiduciaires, protectors, beneficiaries or a defined class of beneficiaries, and any other natural person exercising ultimate control through ownership or other means.

The clarification aligns with Article 55 of Regulation (EU) 2024/1624, the EU Anti-Money Laundering Regulation, which requires companies owned or controlled through legal arrangements to identify the natural persons who ultimately beneficially own those arrangements.

Entities must ensure that RBE filings contain complete identification details, including names, nationalities, dates and places of birth, country of residence, address, identification number, and the nature and extent of the beneficial interest held. Where a filing becomes inaccurate or outdated, entities generally have one month from becoming aware of the change to update their declaration.

For compliance teams, the circular increases the importance of mapping ownership and controls beyond immediate shareholders. Businesses dealing with Luxembourg entities should verify whether trusts, foundations or fiduciary arrangements sit within ownership chains and ensure UBO information reflects the individuals behind those structures.

Failure to maintain accurate RBO information can expose registered entities to fines ranging from EUR 1,250 to EUR 1.25 million under Luxembourg law.

Similar Global Beneficial Ownership Reforms

Luxembourg’s clarification follows a wider global push for beneficial ownership transparency. Vietnam strengthened mandatory UBO disclosure under Decree 296/2026, while Singapore expanded central registers for controllers and nominee arrangements. The UK also operates trust registration and People with Significant Control frameworks to improve visibility into ultimate ownership structures across borders.