Annual Accounts in Luxembourg: Deadlines, eCDF and RCS Filing

This guide focuses on ordinary commercial companies, particularly a SARL, SARL-S or SA. Filing duties also exist for other legal forms, but partnerships, branches, associations and regulated entities have their own conditions. Do not apply a small trading company's checklist unchanged to a fund or a bank. Official filing scope.

Start with the company's legal form, financial year-end and activity. Then ask your accountant to confirm its accounting framework and filing route. A company using a group reporting package should not assume that sending that package to its parent completes the Luxembourg requirements.

For a newly formed company, establish the first year-end and assign responsibility for annual compliance when setting up the bookkeeping. Keep these instructions with the incorporation documents, so a change of accountant or director does not leave an unowned deadline. Our company registration guide covers the setup stage; this guide covers the recurring accounts process.

Under the ordinary LUX GAAP presentation, annual accounts consist of a balance sheet, a profit and loss account, and notes. These documents should be read together. The notes explain matters that the figures alone cannot show, including relevant accounting policies. A management report or an auditor's report may also be needed, depending on the applicable regime. Official accounts guidance.

For your working file, distinguish three categories: the underlying bookkeeping, the final accounts to be approved, and the documents to be filed or published. They overlap but are not interchangeable. A trial balance is a working input, not a substitute for complete financial statements.

Agree a versioning convention with your accountant: draft for review, approved version, and filed version. When a late adjustment affects profit or equity, ask which documents and decisions must be updated. This simple discipline reduces the risk of approving one set of figures and uploading another.

For companies following the ordinary timetable, approval is due within six months of the financial year-end. Filing is due within one month of approval, with an outside limit of seven months after year-end. Earlier approval therefore brings forward the filing deadline: July is not a universal filing window for every December year-end. Official deadlines.

The examples below illustrate that rule; they are not a substitute for checking your company's actual approval date. Keep the meeting date and the filing due date as separate calendar entries. An internal target several weeks before the legal deadline leaves room for queries, missing signatures and technical corrections.

Ask who owns each handover. The accountant may prepare the accounts, the directors organise the approval process, and an authorised filer submits the package. If nobody has explicitly accepted the filing task, do not assume it is included because the bookkeeping is outsourced.

eCDF is the platform used to collect and validate structured financial data. The process depends on whether the company is subject to the Luxembourg standard chart of accounts, the PCN. Some entities are outside the PCN requirement, so confirm the route before choosing forms. PCN guidance.

On eCDF, the preparer selects the relevant financial year and forms, enters or imports the data, resolves validation errors and completes the required validation. Technical consistency checks are useful, but they do not amount to an independent audit of the underlying business records. eCDF procedure.

The crucial distinction is operational: an eCDF validation is not evidence that the accounts have been filed with the RCS. Ask for separate confirmation of the RCS step. If your provider sends a screenshot showing only the eCDF status, request the filing evidence as well.

Before sharing access, ask whether your accountant can act through the appropriate authorised arrangement. Do not send a personal certificate, password or signing credential in an ordinary email. Keep a written record of the tasks delegated and the person responsible for final submission.

The RCS is the Trade and Companies Register, operated by Luxembourg Business Registers. In the filing request, validated eCDF data can be retrieved where applicable; supporting documents are attached in the required format, including PDF/A where specified. RCS submission procedure.

Treat this as a final quality-control checkpoint. Compare the entity name, registration number, financial year, approval date and financial figures with the approved documents. Check that the attachments open correctly and contain the intended version. A familiar filename is not a reliable version check.

After processing, retain the RCS documents bearing the filing evidence. A filing notification is published through RESA, while the availability of the underlying accounts depends on the entity's publication regime. Filing and public disclosure are related but distinct obligations. Publication rules.

Our recommended completion pack is straightforward: approved accounts, approval decision, relevant reports, filing evidence and the provider's confirmation of completion. Store it by entity and financial year. This also gives a future accountant a clear starting point when taking over the engagement.

A filing obligation does not automatically mean a statutory audit is required. For ordinary companies, size classification and its history matter; regulated status and legal form can introduce other requirements. Do not confuse an accountant preparing accounts with an approved statutory auditor reviewing them.

Before planning the close, ask for a documented conclusion covering the entity's category, previous financial years and any audit or supervisory appointment. If a lender or parent company requests a separate assurance engagement, identify that deliverable too. A local filing, a group reporting deadline and a lender's request may require different work.

Our French guide to mandatory audits explains the current thresholds and timing. For a statutory audit, verify the appropriate approval in the CSSF public register, rather than relying only on OEC membership or the brand name of a firm. CSSF approval guidance.

If a deadline has been missed, first identify the unfinished stage: bookkeeping, approval, eCDF validation or RCS submission. Assign an owner and a realistic completion date to each outstanding item. Do not backdate an approval or describe a pending request as a completed filing. Ask the provider to distinguish registry charges from any other legal exposure.

A rejected request is different from correcting accounts already accepted for filing. Read the rejection reason and resolve that issue before resubmitting. For an accepted filing containing an error, the RCS provides amendment and correction procedures; the appropriate action depends on the document and error. Official correction guidance.

Ask whether a correction also affects the approved financial statements, corporate decisions or tax filings. Keep the original submission and the corrected documents with an explanation of the change. A corrected upload should leave a comprehensible audit trail.

Avoid budgeting a single fixed 'late filing fine' from an old article. Check the current registry tariff and ask a professional to assess the consequences of the actual delay. The priority is to establish what remains undone and complete the correct process.

The following is an editorial preparation checklist, not an exhaustive legal list. Agree the final document request with the firm before transferring a large folder. A short inventory of what is available and what is missing often saves more time than an unstructured document dump.

Company information: registration details, articles, financial year-end, relevant corporate decisions, ownership changes and the contact authorised to approve work. Include the prior-year completion pack and any correspondence about unresolved issues.

Bookkeeping: trial balance and ledger, bank statements and reconciliations, sales and purchase records, outstanding receivables and payables, asset schedules, payroll summaries, and tax or VAT balances. Ask which exports the firm can use directly.

Matters requiring discussion: significant contracts, loans, guarantees, transactions with related parties, disputes, unusual transactions and developments after year-end. Flag these explicitly rather than assuming the accountant will infer them from bank movements.

Engagement scope: preparation of accounts and notes, support for approval, eCDF work, RCS filing, handling of queries and any coordination with an auditor. Request separate confirmation of tax-return work. If you need English-language explanations or reporting, include that requirement in the quote request.

Compare proposals on the same scope and assumptions. We do not quote a universal annual-accounts fee: the condition of the records and complexity of the entity materially change the work. Use our guide to choosing an accountant to assess the provider, then request a clearly itemised engagement.