Filing annual accounts in Luxembourg: who files with the RCS, the deadlines (6 + 1 months) and late filing surcharges

Who must file annual accounts with the RCS?

Every year, closing the financial year starts a countdown. For reasons of transparency and to protect third parties, businesses and certain associations must file their annual accounts online with the Trade and Companies Register (RCS), run by Luxembourg Business Registers (LBR).

According to Guichet.lu, the following entities are concerned:

• Capital companies: SA, SARL (including the SARL-S), SECA, cooperative companies and SE.
• Partnerships (SENC and SCS) and sole traders, when their annual turnover excluding VAT exceeds EUR 100,000.
• Luxembourg branches of foreign companies (except credit institutions and insurance or reinsurance companies).
• Groupings (EIG, EEIG) and their branches, as well as all non-profit associations (ASBL) and foundations.

How the register itself works (registration, RCS number, extracts) is covered in our article on the RCS in Luxembourg. Here we focus on what comes back every year: filing the accounts.

The timeline: 6 months to approve, 1 month to file

The annual accounts and the allocation of results must be approved within 6 months of the end of the financial year (legal entities) or of the calendar year (sole traders). They must then be filed within one month of their approval, i.e. no later than 7 months after the year end.

If you are still choosing a legal form, our comparison of the SARL and the SARL-S sets out the differences.

Before filing: present the accounts under the PCN and validate them on eCDF

Unless they are allowed to use IFRS, businesses filing their accounts must present their account balances in line with the standard chart of accounts (PCN) and have their annual accounts validated on the eCDF platform before filing them with the RCS.

eCDF is the State-run platform for the electronic collection of financial data. It standardises three documents: the balance sheet, the profit and loss account and the account balances. There are two ways to prepare them there:

• enter the data in the standardised (PDF) forms available on the platform;
• upload an XML file generated by the filer’s accounting tool.

Filing online with the RCS: LuxTrust, the accounting package and PDF/A

Once the accounts are validated on eCDF, the filer submits the accounting package electronically to the RCS using a LuxTrust certificate. When filing, they tick the box confirming that the accounts were validated on eCDF, and the LBR then automatically collects the balance sheet, the profit and loss account and the account balances.

The other, so-called unstructured documents are attached in PDF/A format:

• the notes to the accounts;
• the management report;
• the report of the person responsible for auditing the accounts.

Once the filing has been processed, the documents carrying the virtual proof-of-filing label can be downloaded from the filer’s personal space on the RCS website (under “mes commandes”). Filing fees, due for each filing, follow the tariffs published by the LBR.

After filing: the RESA notice and public access

The filing notice is published in the electronic compendium of companies and associations (RESA) on the day of filing, or on a set date chosen by the filer when creating the request, within 15 days of the filing. It takes the form of a new line inserted in the RESA.

The filed accounts can then be consulted by the public, as PDFs on the RCS website. The law provides exceptions: for sole traders, EIGs and certain SENCs and SCSs, the notice is not published and the accounts cannot be consulted.

Filing late? The filing fees are increased

The LBR increases the filing fees for financial data filed outside the legal deadlines. Lateness is calculated from the year-end date and the maximum period of 7 months. The surcharges are calculated automatically and apply to all legal entities, except in particular non-profit associations (ASBL), foundations, agricultural associations, special limited partnerships and pension savings bodies.

The example column is an illustrative calculation; the register’s automatic calculation is what counts. 2025 accounts not yet filed in early November 2026 are therefore already late.

The year-end checklist

1. 1
   Close the year: complete entries, supporting documents attached, accounts classified under the PCN.
2. 2
   Prepare the balance sheet, the profit and loss account and the notes, with your fiduciaire or accountant if you have one.
3. 3
   Have the accounts approved within 6 months by the body your legal form requires (partners’ or shareholders’ meeting…).
4. 4
   Validate the balance sheet, the profit and loss account and the account balances on eCDF.
5. 5
   File the package with the RCS using LuxTrust within one month of approval, with the notes and reports in PDF/A.
6. 6
   Choose the publication date of the RESA notice (same day or within 15 days) and download your proof of filing.

Most of the work happens upstream: books kept up to date all year make the year end much faster. If you are looking for a professional to help, read our article on chartered accountants in Luxembourg.

To find out more, explore Zuelen’s features and what Zuelen offers for companies.