KYC when forming a company in Luxembourg
Published on 10 October 2026 · Updated on 10 October 2026
In short
KYC for company formation in Luxembourg means that the bank, the notary and the registered office provider must, under the law of 12 November 2004, identify the client and its beneficial owners, understand the purpose of the relationship and, where necessary, the source of funds. They ask for identity documents, a chart, an activity description and proof of the capital.
Definition
KYC (know your customer) refers to the due diligence measures that a professional subject to anti-money laundering legislation applies to its client: identifying and verifying identity, identifying beneficial owners, understanding the nature of the relationship and monitoring it over time.
The legal framework in brief
- Text
- Amended law of 12 November 2004
- Professionals covered
- Banks, notaries, registered office providers, lawyers and others
- Beneficial owner
- More than 25% of the capital or votes
- Source of funds
- Verified where necessary
Who asks for what
| Counterparty | What it generally asks for | Why |
|---|---|---|
| Bank | Identity and address of each shareholder, manager and beneficial owner; business plan; source of funds and wealth; tax residence | To open an account and accept flows whose origin and destination it understands |
| Notary | Identity of the parties appearing, powers of attorney, documents of corporate shareholders, information on the capital | To receive a notarial deed after verifying the identity and capacity of the parties |
| Registered office provider | Identity of shareholders and managers, beneficial owners, activity, source of funds depending on the profile | To provide an office to a company whose beneficiaries and activity it must know |
| Lawyer, licensed accountant | Identity of the client and beneficial owners, nature of the engagement | To meet their own professional due diligence obligations |
Each professional applies its own procedure and risk assessment: the exact documents and their format vary.
Prepare your KYC file
- 1
Draw up the chart
From the company to be formed down to the individuals, with the percentages of capital and voting rights at each level.
You, with us - 2
Gather identity documents
Passport or identity card and recent proof of address for each shareholder, manager and beneficial owner.
Shareholders and managers - 3
Document the source of funds
Statement of the account the money comes from and a document explaining its origin: salary savings, sale of an asset, dividends, gift.
Shareholders - 4
Describe the activity
Customers, suppliers, countries involved, expected flows. A clear project reduces questions.
You - 5
Answer consistently
The same information is given to each counterparty: a contradiction between two files triggers additional requests.
You, with us
Source of funds and source of wealth
The source of funds concerns the money brought into the company for this transaction. The source of wealth concerns how the shareholder built up all of their assets. The bank may ask for both, in particular for a large capital, a politically exposed shareholder or funds coming from abroad. We cannot guarantee that an account will be opened: the decision belongs to the bank.
Templates to help you prepare
Two free templates help you gather the information in the expected order: the KYC questionnaire for shareholders, managers and beneficial owners and the source of funds statement. They are preparatory documents, not official forms: each bank keeps its own form.
To identify beneficial owners correctly, see the definition of the beneficial owner; for the bank, see the guide to opening a business bank account.
Next step
A consistent KYC file from the start
We prepare with you the chart, the documents and the presentation of the project for the bank, the notary and the registered office provider.
Frequently asked questions
Why does the bank ask for so many documents?
Because the law of 12 November 2004 requires it to identify its client and beneficial owners, understand the purpose of the relationship and monitor transactions, including the source of funds where necessary. Without these elements, it cannot open the account.
How do I prove the source of funds?
With a statement of the account the funds come from and a document explaining their origin: payslips, a sale deed, a dividend statement, a gift or inheritance deed. Our statement template helps present these elements. Each bank keeps its own form, so ask which documents it prefers.
Is KYC repeated for each counterparty?
Yes. The bank, the notary and the registered office provider are each subject to their own obligations and cannot rely on another one's file. Preparing a single, consistent file avoids answering different questions several times. Each applies its own procedure and risk assessment.
Must the same beneficial owners be declared to the bank and to the RBE?
They must be consistent. The RBE and the bank apply the same legal definition; a discrepancy between the two draws attention and may lead the bank to ask for explanations. The documents given to one must therefore match those given to the other, in particular the percentages of capital and voting rights.
What happens for a non-resident shareholder?
The documents requested are the same, often with certified copies, apostilles and more detailed questions on tax residence and source of funds. Opening the account generally takes longer. It is better to gather these documents at the very start of the project.