CSSF communiqué relating to the publication of Q&A CNC 26/038, entitled “Large associations, associations recognised as being of public utility and foundations: targeted clarifications on the new accounting regime introduced by the Law of 7 August 2023” (only in French)

Key dates

01 January 2023

- Earliest financial year start date from which adjusted size criteria under Articles 35 and 47 LRCS may be applied to undertakings and groups, which indirectly affects categorisation and accounting obligations of entities subject to commercial‑law size criteria

07 August 2023

- Law of 7 August 2023 introducing the new accounting regime for associations and foundations is adopted, setting the legal basis for reclassification and annual accounts obligations

01 January 2024

- Default application date of the adjusted LRCS size criteria for undertakings and groups where early application from 01 January 2023 is not chosen

Financial year 2025

- New LRCS size thresholds start to determine the categorisation of pre‑existing Luxembourg undertakings and, by analogy, influence assessments of “medium‑sized” status relevant to associations

Autumn 2026

- CNC plans to publish an accounting guide dedicated to the new accounting regime for not‑for‑profit associations (ASBLs) classified as small, medium‑sized and large, as well as public‑utility associations and foundations

Suggested considerations

• Identify whether the organisation qualifies as a large association, an association recognised as being of public utility or a foundation under the Law of 7 August 2023, and document the classification decision with reference to Articles 18, 36 and 52 of that law.
• Update internal accounting policies to require annual accounts to be prepared in accordance with the regime for undertakings referred to in Article 47 LRCS, including minimum content (balance sheet, profit and loss account and notes) and disclosure requirements.
• Decide formally whether to adopt the PCN on a voluntary basis or to maintain an internal chart of accounts, and record this decision in accounting governance documents approved by the board or governing body.
• Where PCN is not adopted, design and implement a detailed and documented mapping from internal general ledger accounts to LRCS statutory balance sheet and profit and loss layouts to ensure accurate preparation and filing of annual accounts.
• Review and, where necessary, redesign annual accounts templates to comply with LRCS layouts while making only permitted adaptations (for example, titles and subtotals) that maintain clarity, comparability and consistency over time.
• Establish procedures to ensure timely filing of annual accounts with the RCS in classic LRCS format, including quality controls around completeness and correctness of notes and disclosures.

What changed

• - Large not‑for‑profit associations, associations recognised as being of public utility and foundations are required to prepare annual accounting documents consisting at a minimum of annual accounts in accordance with the accounting regime applicable
• These entities fall within the regime applicable to “medium‑sized undertakings”, which drives the required content and level of detail of their annual accounts (balance sheet, profit and loss account and notes).
• The law and the CNC Q&A confirm that large associations, public‑utility associations and foundations are not legally required to use the Standard chart of accounts (Plan comptable normalisé, PCN) or to submit standardised financial data via the eCDF
• Although exempt from mandatory PCN use and eCDF standard data collection, these entities must still file their annual accounts with the Luxembourg Trade and Companies Register (RCS) using statutory LRCS layouts in “classic” format (i.e. non‑standardi
• Large associations, public‑utility associations and foundations are exempt from the obligation to file the PCN trial balance (balance générale) via the eCDF platform, even though they may still choose to use PCN on a voluntary basis.
• The CNC confirms that not‑for‑profit entities may voluntarily adopt PCN while retaining flexibility in their internal chart of accounts; where PCN is not adopted, they must ensure robust mapping from internal accounts to the statutory LRCS balance sh

Who is affected

• Large not‑for‑profit associations (ASBL) established in Luxembourg and classified as “grandes associations” under the Law of 7 August 2023.
• Associations recognised as being of public utility under Article 36 of the Law of 7 August 2023.
• Foundations established under Luxembourg law and falling under the new accounting regime introduced by the Law of 7 August 2023.
• Boards and finance/compliance functions of Luxembourg‑based not‑for‑profit bodies that are supervised or otherwise monitored by the CSSF or that interact with CSSF‑regulated institutions (for example, as counterparties, beneficiaries or sponsors).
• Audit firms and accounting service providers supporting the preparation and filing of annual accounts for large associations, public‑utility associations and foundations.
• Organisations preparing for classification as small, medium‑sized or large associations under the Law of 7 August 2023 in anticipation of the forthcoming CNC accounting guide.