CSSF, the ECB and the banks behind a Luxembourg business account

To open a bank account in Luxembourg for a company, you usually deal with a credit institution supervised under the euro area’s Single Supervisory Mechanism. The CSSF, the Commission de Surveillance du Secteur Financier, supervises the less significant Luxembourg banks, such as Banque Raiffeisen; the European Central Bank supervises the significant ones. Its list with a 1 July 2026 cut-off names Spuerkeess and Banque Internationale à Luxembourg (BIL) as significant Luxembourg banks and places BGL BNP Paribas, ING Luxembourg, Société Générale Luxembourg and Banque de Luxembourg inside significant groups. Payment and e-money institutions are separate: since 30 July 2021 the CSSF alone authorises them, and a company that wants to provide payment services needs its own CSSF licence.

FGDL deposit protection for a Sàrl or SA

The Fonds de garantie des dépôts Luxembourg (FGDL) protects deposits up to EUR 100,000 per person and per bank. Companies of every size are eligible whatever their registered address; deposits that banks, financial institutions, investment firms and insurers hold for their own account are excluded, as are investment funds. Foreign-currency deposits count but are repaid in euros, within seven working days of the deposits becoming unavailable. The members are the Luxembourg credit institutions, POST Luxembourg for its postal financial services and branches of banks based outside the EEA. Payment and e-money institutions are not members; they must safeguard client funds instead.

The capital deposit and Luxembourg’s 2026 Sàrl reform

In Luxembourg the bank has traditionally come before the company. For a cash contribution the founders pay the capital into a blocked account and obtain a certificat de blocage, which the notary relies on to execute the deed before issuing a release certificate. Guichet.lu, the government portal, says the bank may be in Luxembourg or abroad, though it recommends a Luxembourg one.

The law of 18 May 2026, in force since 2 June 2026, changed this for the Sàrl. Its EUR 12,000 minimum capital must still be fully subscribed at incorporation but may be paid within twelve months, or within any shorter period the articles set. Capital above the minimum, share premium and contributions in kind are still paid at incorporation; votes on shares with overdue called payments are suspended, and unpaid shareholders are listed after the balance sheet. A Sàrl can therefore be incorporated before any bank account exists, though the bank’s checks still follow. The SA is unchanged: EUR 30,000 minimum capital, at least a quarter paid up at incorporation.

What Spuerkeess, BGL BNP Paribas, BIL and POST Finance publish

On the pages checked, none of these four sets a residence or nationality condition for the owners; they differ on route and identification:

Provider Type Route and identification What it publishes
Spuerkeess Bank, supervised by the ECB Online request, also for a company being incorporated; opens only after its decision-making bodies approve RCS and RBE extracts under three months old, an organisation chart down to the individuals, ID copies certified when not from the EU, the origin of funds of beneficial owners and 10% shareholders
BGL BNP Paribas Bank, BNP Paribas group Online request form for SMEs, but “opening cannot be done remotely: proper identification required” Draft articles, business plan and ownership chart for a company being set up; articles, register extracts and balance sheets for an existing one
BIL Bank, supervised by the ECB Contact form, then a relationship manager Documents set by legal status and business sector
POST Finance POST Luxembourg’s postal financial services, an FGDL member Physical identification required; applications approved within a month Current accounts only for firms headquartered in Luxembourg; blocking certificate sent to the notary within 5 to 10 working days of the capital arriving

The ABBL, the Luxembourg Bankers’ Association, also publishes an SME contact list; its July 2026 edition adds Banque Raiffeisen, HSBC Luxembourg and payment or e-money institutions such as Vivid Money, and is expressly not an endorsement.

The Luxembourg KYC file: RCS and RBE extracts and the UBO form

The ABBL’s December 2024 guide for commercial companies, drafted with the CSSF consulted, sets out the minimum file, to which a bank may add:

  • the articles and a recent extract from the Trade and Companies Register (RCS);
  • a recent extract from the Register of Beneficial Owners (RBE) and a signed UBO declaration form, which the guide says CSSF regulation requires;
  • an organisation chart with every holding layer and percentage;
  • the activity, NACE code and expected transactions, and for a new company a business plan;
  • the origin of the funds, backed by documents such as a sale agreement or a dividend resolution;
  • ID for each beneficial owner, director and signatory, with specimen signatures;
  • a FATCA and CRS self-certification and tax numbers.

Spuerkeess adds the business permit (autorisation d’établissement) where the activity needs one, any domiciliation agreement, three years of accounts in PDF and XML, and, for a new company, the blocking certificate, VAT number and LEI code.

Opening from abroad: CSSF video identification versus bank policy

The law does not require a Sàrl’s shareholders or gérant to live in Luxembourg, and the CSSF’s FAQ on video identification lets a bank identify a company’s representatives and beneficial owners by live video, though only where there is no suspicion, no doubt about the data and no higher risk. Offering that route is bank policy. BGL BNP Paribas says accounts cannot be opened remotely, POST Finance requires physical identification, and the Spuerkeess and BIL pages do not say.

Two legal rules tie the company to Luxembourg. A company domiciled with a third party must use an agent authorised under the law of 31 May 1999, such as a bank, lawyer, auditor or expert-comptable, under a written agreement, and a trading company needs a business permit, which requires a physical establishment in Luxembourg and a manager in effective charge.

Why Luxembourg applications stall: the ABBL and parliament on the record

  • No duty to accept. The ABBL states that Luxembourg banks are not obliged to open business accounts; they apply a customer acceptance policy.
  • Country links. The owners’ origin, links with certain countries and where customers are located are risk factors; each bank may keep its own, longer, high-risk country list.
  • No identified beneficial owner, in which case the bank cannot start the relationship.
  • A legal form that does not fit the activity, which the ABBL says can delay the request or end in refusal.
  • Annual accounts filed late at the RCS.
  • An incomplete file: the account stays inactive until identification is complete.
  • The sector, which POST Finance names among its acceptance criteria.

Parliament has acknowledged the problem: the justice committee’s report on the 2026 reform says the old rule often forced founders to open a bank account first and could delay incorporation because of the banks’ verification duties, and the Chambre des Métiers called the lack of a bank account a major obstacle.

Euro accounts, the LU IBAN and SEPA

Accounts are held in euros. A Luxembourg IBAN has 20 characters: LU, two check digits, a three-digit bank code and the account number. Luxembourg is inside SEPA, so euro transfers to the other SEPA countries work as at home, and the FGDL counts foreign-currency deposits towards the EUR 100,000 limit.

Ready-made Sàrl or new formation in Luxembourg

A bank account belongs to the company and stays with it when the company changes hands; what changes is that the bank re-runs its due diligence on the new owners, directors and signatories and may keep the account, ask for more documents or close it. Our own offer page lists Luxembourg among the places where pre-banked shelf companies are not readily available, so with a ready-made Luxembourg Sàrl plan for the bank to onboard you as a new client. A new Luxembourg formation can pay the Sàrl capital at once through the blocked account or within twelve months. We can supply either and help prepare the bank application; the decision stays with the bank. See our guide to shelf companies with bank accounts, the pre-banked shelf company page and the Luxembourg hub.

Frequently Asked Questions about opening a bank account in Luxembourg

Can I open a Luxembourg business bank account from overseas?

Partly. Company law sets no residence rule for a Sàrl’s owners or gérant, and the CSSF lets banks identify representatives and beneficial owners by live video where the risk is not higher. Bank policy is stricter: BGL BNP Paribas says accounts cannot be opened remotely and POST Finance requires physical identification. Prepare the file from abroad, but expect to be identified in person at least once.

Do I still need a blocking certificate to form a Luxembourg Sàrl?

Not necessarily, since 2 June 2026. A Sàrl’s EUR 12,000 minimum capital must still be fully subscribed at incorporation but may be paid within twelve months, so the deed can be signed before any bank account exists. Founders who pay at once, and anyone forming an SA with cash, still use the blocked account and the certificat de blocage.

Can a non-resident open a bank account in Luxembourg?

For a company, the law allows it: a Sàrl’s shareholders and gérant may live anywhere. Each bank decides under its own acceptance policy, weighing the owners’ countries, the origin of funds and the structure, and has no duty to open business accounts. POST Finance offers current accounts only to firms headquartered in Luxembourg, and BGL BNP Paribas requires identification that cannot be done remotely.

Are company deposits protected in Luxembourg?

Yes. The FGDL covers deposits up to EUR 100,000 per person and per bank for companies of every size and registered address. Deposits that banks, financial institutions, investment firms and insurers hold for their own account are excluded, as are investment funds, and foreign-currency deposits are repaid in euros. Payment and e-money institutions are not FGDL members; they safeguard client money instead.

Which documents does a Luxembourg bank ask a company for?

The core file is the articles, RCS and RBE extracts, which Spuerkeess wants under three months old, a UBO declaration form, an organisation chart, ID for owners, directors and signatories, and a FATCA and CRS self-certification. Add the origin of funds, a business plan for a new company and, where relevant, the business permit, the domiciliation agreement and the blocking certificate.

Do I need a licence to run a payment company in Luxembourg?

Yes, if the company itself will provide payment services or issue electronic money. Since 30 July 2021 the CSSF alone grants, refuses and withdraws the authorisations of payment and e-money institutions, a power that used to sit with the Minister of Finance. That licence is separate from opening the company’s business account, which each bank decides under its own acceptance policy.

We accept cryptocurrency payments Get details →