Small, Medium, or Large ASBL? The Simple Guide to (Finally) Understanding Your Category

In our previous article, we saw that the September 23, 2025 deadline has passed, making it urgent to get your ASBL compliant.

The very first step, before you do anything else, is a "self-assessment". The new Law of 7 August 2023 sorts you into a size category, and your legal obligations depend entirely on it.

Don't worry, this is much simpler than it sounds. Forget the legal jargon. Here’s how to find out which box you fit into in 5 minutes.

1. The Golden Rule: "2 out of 3, for 2 Years"
To determine your size, it all comes down to one simple rule. Your ASBL is measured against 3 criteria at your financial year's closing date.

The number of employees (in full-time equivalents, or FTE).
Your total annual revenues.
Your total assets (what you own).

The law states that your category changes (or is defined) if you exceed (or stop exceeding) at least 2 of these 3 criteria for two consecutive financial years.

To know where you stand today, you must look at your numbers for the last two closed years (e.g., 2023 and 2024).

2. The 3 Criteria Explained (in Plain English)
Here are the thresholds that define a "Small ASBL". This is the category that covers the vast majority of non-profits in Luxembourg.

Criterion 1: Personnel (Employees)

"Small" Threshold: Fewer than 3 employees (FTE).
Plain English: This only counts staff on an employment contract. Your volunteers do not count. If you have two people working half-time (2 x 20h/week), that counts as 1 FTE. It's an average number over the year.

Criterion 2: Revenues (Receipts)

"Small" Threshold: 50,000 euros.
Plain English: For a small ASBL, this means "receipts" (cash you received). This includes:
Membership fees
Donations
Subsidies (except those for a specific investment)
Income from your events (drink sales, raffles, etc.)
Important: A bank loan you receive is not revenue.

Criterion 3: Assets (What You Own)
"Small" Threshold: 100,000 euros.
Plain English: This is everything your association owns at the end of the year. Since small ASBLs often don't have a balance sheet, you just need to make a simple inventory. Add up:
The cash in your cash box
The money in your bank account(s)
The value of your inventory (if significant, e.g., a stock of team shirts for sale)
The value of your equipment, furniture, etc. (if they are still worth something)
The value of any real estate the ASBL owns

3. The Result: So, Are You "Small", "Medium", or "Large"?

Now, just apply the golden rule.

✅ You are a "Small ASBL" if...

You do not exceed more than one of these 3 thresholds, for two years in a row.

Example: Your sports club has 4 employees (FTE) (you exceed criterion 1). BUT you only have €30,000 in revenue (under) and €40,000 in assets (under).

Result: You only exceed one criterion. You are therefore a "Small ASBL".

✅ You are a "Medium ASBL" if...

You exceed at least 2 of the 3 "Small" thresholds (above), BUT you stay below the "Large" thresholds.

"Large" thresholds: 15 employees, €1,000,000 revenue, €3,000,000 assets.

✅ You are a "Large ASBL" if...

You exceed at least 2 of the 3 "Large" thresholds (15 employees, €1M revenue, €3M assets) for two years in a row.

Note for "new" ASBLs: If your association was created after September 23, 2023, you have no history. The law requires you to make a good-faith estimate of these 3 criteria for your first financial year to determine your category.

Small, Medium, or Large ASBL? The Simple Guide to (Finally) Understanding Your Category

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