CSSF press release 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)

What Changed

• - Large associations, associations recognised as being of public utility and foundations are now subject to the accounting regime applicable to “medium‑sized undertakings” under the amended Luxembourg Register of Commerce and Companies (LRCS) pursuan
• Annual accounts for affected entities must include a non‑abridged balance sheet, a profit and loss account (at least in abridged format), and notes to the accounts containing disclosures required by the LRCS.
• Affected entities must use statutory LRCS layouts for the balance sheet and profit and loss account and file their annual accounts in classic format with the Luxembourg Trade and Companies Register (RCS).
• Large associations, public‑utility associations and foundations remain exempt from the mandatory use of the Standard Chart of Accounts (Plan Comptable Normalisé – PCN) and from eCDF standard data collection obligations.
• Affected entities may voluntarily adopt the PCN; if they do not adopt PCN, they must maintain an internal chart of accounts and ensure robust, documented mapping between internal accounts and statutory LRCS balance sheet and P&L layouts.
• The Q&A confirms that not‑for‑profit entities may adapt standard LRCS layouts (for example, line‑item titles, subtotals and additional captions) to reflect the specific nature of their activities, provided that such adaptations remain consistent over

Suggested Considerations

• Identify all Luxembourg associations, public‑utility associations and foundations within or related to the group that are impacted by the Law of 7 August 2023 and confirm their size classification (small, medium‑sized, large) and whether they fall under the “medium‑sized undertakings” regime.
• Review existing accounting policies, charts of accounts and annual accounts formats for affected entities to ensure alignment with LRCS statutory layouts, including non‑abridged balance sheet, appropriate profit and loss format, and required notes disclosures.
• Decide at governing‑body level whether each affected entity will voluntarily adopt the PCN or maintain an internal chart of accounts, documenting the rationale, governance approvals and compliance impacts of the chosen option.
• Where PCN is not adopted, design, implement and document a robust mapping from the internal chart of accounts to the statutory LRCS balance sheet and profit and loss layouts, ensuring audit‑ready documentation and traceability.
• Update accounting systems and reporting tools for affected entities to support LRCS statutory layouts, consistent layout adaptations, and classic‑format filing with the RCS, including necessary changes to interfaces and data capture.
• Establish or update internal accounting manuals and procedures for not‑for‑profit entities to incorporate CNC Q&A 26/038 clarifications, including rules on layout adaptations, consistency over time, and comparability of annual accounts.

Key Dates

Who is Affected