Independent review, verification and assurance in Luxembourg
Independent review, verification and assurance engagements for companies, funds in wind-down, and regulated and professional businesses — performed outside the statutory audit perimeter. In Luxembourg, a substantial range of review and assurance work does not require authorisation as an approved statutory auditor (réviseur d'entreprises agréé, Law of 23 July 2016) or as a lawyer (Law of 10 August 1991); it sits with commissaires aux comptes, experts-comptables, and specialised service providers. That is the ground this practice covers — scoped precisely, documented to a standard a counterparty or regulator can rely on.
Commissaire aux comptes mandates
Under Articles 443-1 et seq. of the Law of 10 August 1915 on Commercial Companies, an S.A. — and certain S.à r.l. — below the statutory audit thresholds must appoint one or more commissaires aux comptes. The mandate carries unlimited powers of supervision and inspection over the company's operations, accounting records and inventory verification methods, and concludes in an annual supervisory report to the general meeting. The appointment does not require a CSSF audit licence. We accept commissaire mandates for holding, investment and operating companies, and structure the supervisory file so that it stands on its own in a later audit, transaction or liquidation. The same supervisory logic extends to wind-downs: mandates as auditor in liquidation and as commissaire appointed to examine the closing accounts — including for specialised investment funds under Article 47(9) of the SIF Law.
Limited reviews and assurance engagements
Contractual, non-statutory engagements modelled on the international standards: limited reviews of financial statements and interim accounts providing negative (moderate) assurance (ISRE 2400 / 2410); assurance reports on internal controls, service organisations and KPIs outside the statutory audit (ISAE 3000 / 3402); and accounting investigations and contractual due diligence — quality of earnings, balance-sheet positions, working capital — in acquisitions and restructurings.
Agreed-upon procedures and verifications
Factual-findings work under ISRS 4400: verification of qualifying expenses for subsidies and grants (including professional-training co-financing under the amended Grand-Ducal Regulation of 7 August 2012 and R&D state aid), covenant and ratio verifications for lenders, royalty and lease verifications, and compilation engagements (ISRS 4410). The report states procedures and findings — no opinion, no ambiguity about scope.
Regulatory and tax compliance reviews
Operational reviews of AML/KYC, KYA and UBO files against the amended Law of 12 November 2004 and the RBE Law of 13 January 2019; FATCA and CRS reviews — self-certifications, account classification and reporting extractions under the Laws of 24 July 2015 and 18 December 2015; and control-framework and governance testing consistent with CSSF Circular 12/552 for entities that outsource internal-audit work.
Engagement framework
| Engagement | Standard / reference | Governing law |
|---|---|---|
| Statutory supervisory review (commissaire aux comptes) | Art. 443-1 et seq. | Company Law of 10 August 1915 |
| Limited review | ISRE 2400 / 2410 | Law of 10 June 1999 (OEC framework) |
| Assurance on controls & service organisations | ISAE 3000 / 3402 | Law of 10 June 1999 (OEC framework) |
| Agreed-upon procedures | ISRS 4400 / 4410 | Law of 10 June 1999 (OEC framework) |
| AML/KYC & UBO file verification | AML/CFT framework | Law of 12 Nov 2004; Law of 13 Jan 2019 (RBE) |
| FATCA / CRS review | FATCA / CRS | Law of 24 Jul 2015; Law of 18 Dec 2015 |
Perimeter
These engagements are deliberately structured outside the reserved perimeter: they are not statutory audits, and no report is issued that the law reserves to a réviseur d'entreprises agréé. Where an entity's size, sector legislation or fund documentation requires an approved statutory auditor, we scope the mandate accordingly and work alongside the appointed réviseur or expert-comptable rather than in their place. Scope, standard and intended use of each report are fixed in the engagement letter before work starts.
