Changing beneficial owner details in the UBO register
Published on 10 October 2026 · Updated on 10 October 2026
Please note. Business Registration SARL-S is a private advisory firm. It is not the Luxembourg Business Registers (LBR), the economic interest grouping that officially runs the RCS, the RBE and the RESA. Filings and registrations are made with the LBR, at the fees it publishes.
In short
To update the UBO register in Luxembourg (RBE), an entity must request the change within one month of the day it knew, or should have known, of it: a share transfer, a change of control or a beneficial owner moving abroad. The update costs €15 excl. VAT; a late request is subject to a surcharge of €50 to €500.
Figures to remember
- Deadline
- 1 month after the change
- Update fee
- €15 excl. VAT
- Registration by the LBR
- Within 3 working days
- Criminal fine
- €1,250 to €1,250,000
Changes that require an update
- Transfer of shares that takes a natural person above or below the 25% threshold.
- Entry of a new partner who is a natural person, or of a company whose beneficial owner changes.
- Change of control by other means: shareholders’ agreement, voting rights, power to appoint managers.
- Change of managers where they are declared because no beneficial owner has been identified.
- Change of address, country of residence, nationality or name of a beneficial owner.
- Death of a beneficial owner or transmission of their shares.
Updating the UBO register
- 1
Analyse the change
We rebuild the chain of ownership and control after the transaction to identify the beneficial owners.
businessregistration.lu - 2
Gather the supporting documents
Official identity document where the person has no Luxembourg identification number, and documents required by the Grand-Ducal regulation.
Company and beneficial owners - 3
File the update
Electronic request on the LBR platform, with a LuxTrust certificate, by the company, its agent or the notary who received the deed.
Company, agent or notary - 4
Registration and receipt
The LBR registers the data within 3 working days if the file is compliant. Otherwise, it invites the filer to regularise within 15 days.
LBR - 5
Keep the file
The company keeps at its registered office the information on its beneficial owners and the documents supporting it.
Company
The penalties are real
Failing to request the update within the deadline, or knowingly declaring inaccurate or outdated information, is punishable by a fine of €1,250 to €1,250,000. A beneficial owner who does not give their information to the company faces the same fine. If the company does not answer an LBR verification request within 30 days, the LBR may, among other measures, impose a penalty of €40 per day or proceed to administrative striking off.
RCS and UBO register: two separate filings
A share transfer or a change of manager is filed first with the RCS and then, if the beneficial owners change, with the UBO register. Both registers are kept by the LBR but the filings are separate and paid separately. See filing a change with the RCS.
Professionals subject to anti-money-laundering obligations, such as banks, must report to the LBR any discrepancy they find within 30 days. An up-to-date UBO register therefore also avoids blockages when opening a bank account. If your UBO register has not been updated for a long time, see our page on fixing the UBO register.
Next step
A change to declare in the UBO register?
Describe the transaction: we identify the beneficial owners and file the update within the deadline.
Frequently asked questions
What is the deadline to update the UBO register?
The Law of 13 January 2019 requires the update to be requested within one month of the moment the entity knew, or should have known, of the event. For a share transfer, the period in practice runs from the transfer itself, not from its filing with the RCS.
How much does a UBO register update cost?
According to the LBR fee schedule consulted on 10 October 2026, an update costs €15 excl. VAT, plus 17% VAT. A late declaration is surcharged by €50 in the second month, €200 in the third and fourth months and €500 from the fifth month.
Does the UBO register need updating when the manager changes?
Only if the manager appeared in the register as senior managing official because no beneficial owner was identified, or is a beneficial owner themselves. A change of manager is in all cases filed with the RCS. We check both registers on every transaction.
Is there an annual confirmation of the UBO register?
The consolidated text of the law as at 1 February 2025 provides for no annual confirmation. Updates are triggered by events, not by the calendar. The company must nevertheless ensure that the information remains adequate, accurate and current, and answer LBR verification requests.
Who can file the update?
The entity itself, an agent it appoints or the notary who received the amending deed. Filing is electronic and made with a LuxTrust certificate on the LBR platform, which the filer must therefore hold. An assistance desk exists, for a surcharge of €20 per declaration.