Last Updated on July 5, 2025 by Arnaud Collignon
1. General Provisions
What documentation should be consulted?
- Amended Law of 18 December 2015
- Amended Grand-Ducal Regulation of 15 March 2016
- ACD official FAQs
- Circular ECHA No. 4
- CRS XSD schemas and status message formats
- OECD publications and tools (AEOI portal, guides, TIN on the Web)
Which jurisdictions are covered?
- Reportable jurisdictions: EU member states and countries with information exchange agreements with Luxembourg
- Partner jurisdictions: defined by law and Grand-Ducal regulation
Optional provisions for FIs
- Outsourcing CRS obligations to service providers
- Applying enhanced due diligence procedures
- Accounts <250,000 USD may be excluded
- Applying thresholds or expanded definitions as provided in CRS law
2. Financial Institutions
Who is affected?
- UCIs, SIFs, SICARs, pension funds, RAIFs, investment firms, etc.
Investment entity status
- An entity qualifies if it manages financial assets on behalf of clients
Luxembourg-specific rules
- No officially recognized low-risk non-reporting FIs
- E-money institutions are generally not considered depository institutions unless exceptions apply
3. Financial Accounts
Removal of low-risk excluded accounts
- As of 2018, these accounts are no longer excluded from CRS
Supplementary Pension Schemes (RCP)
- Classified as financial accounts, even during the accumulation phase
Derivatives
- Not considered financial accounts unless held in a custodial account
4. Due Diligence
Mandatory wider approach
- All accounts must be reviewed, even if the jurisdiction is not yet a partner
NIF / TIN collection
- Required for all new accounts
Self-certifications
- No specific form mandated, but must determine tax residence
- Must be collected within 90 days of account opening
5. Reporting
Only secure transmission channels allowed
- Only via third party providers
Zero reporting requirement
- Mandatory even if no reportable accounts are identified
Technical identifiers (RFI_IDENTIFIER)
- Composed of a Luxembourg registration number + extension (e.g. M00000000)
Foreign TINs
- Must be specified for each jurisdiction
- If not available: use code #NTA001#
Closed or dormant accounts
- Must be reported using specific XML attributes
Validation and schemas
- Data messages: XSD v2.0
- Status messages: XSD v3.0
- Automatic validation with ACK/NAK, VAL/WAR/ERR messages