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UBO register and reporting obligation

The UBO register plays a crucial role in preventing money laundering and fraud. As an organisation, company or trust, you must comply with the registration requirement. And as an AML institution, you are obliged to correctly identify UBOs. But what exactly is a UBO, how does the UBO register work, and what should you do if the information is incorrect? In this article, you will read everything about the registration and reporting obligation and the latest changes in legislation and regulations.

What is a UBO?

A UBO (Ultimate Beneficial Owner) is the natural person who ultimately owns or controls an organisation. This may be someone who (directly or indirectly) holds more than 25% of the shares, voting rights, or ownership interest. Individuals who exercise effective control in another way also fall within this definition. In our article on UBOs, we explain more about UBOs per legal structure.

 

What if no one holds more than a 25% interest?

In that case, you designate a pseudo-UBO. These are usually the statutory directors or individuals in a senior management position. In companies this occurs less frequently, but in foundations and associations it is more common. In our article on pseudo-UBOs, you will find practical tips for identifying pseudo-UBOs.

Please note: when the AMLR enters into force in mid-2027, the definition of UBO will change. A person with 25% or more ownership or control will then be considered a UBO (currently this is more than 25%).

 

What is the UBO register and why does it exist?

The UBO register is managed by the Chamber of Commerce and falls under the Trade Register Act. Its purpose is to combat money laundering, fraud and terrorist financing. Since 2020, registration of UBOs has been mandatory. Failure to register may result in fines or sanctions.

 

Two UBO registers in the Netherlands

  1. UBO register for legal entities: For companies, foundations and associations. Most organisations must register in this register. On the Chamber of Commerce website, you will find the obligations and exceptions per legal structure.

  1. UBO register for trusts and similar legal arrangements: Aimed at trust offices and legal arrangements such as mutual funds. Trustees who reside or are established in the Netherlands, or who reside outside the EU but have a business relationship in the Netherlands, must register.


For AML institutions

As a gatekeeper, you are required to establish the identity of the UBO when entering into new business relationships. You must investigate who ultimately owns or controls the client. This may be evident from shareholdings, voting rights, ownership interests or other control mechanisms. If no one holds more than a 25% interest, you designate a pseudo-UBO.

Reporting discrepancies to the UBO register

Since 1 October 2024, you are required to report discrepancies between the UBO register or a certified UBO extract and your own determination of the UBO to the Chamber of Commerce.

Examples of reports include:

  • Missing UBOs
  • Individuals incorrectly registered as UBOs
  • Incorrect interest or size of the interest

To report a discrepancy, you need a Chamber of Commerce account and authorisation. You can find out how to apply on the Chamber of Commerce website.

Please note: Supervisory authorities actively monitor compliance and take violations seriously. Failure to comply with the reporting obligation may result in sanctions, such as fines.

For organisations and trusts

Most organisations are required to correctly register their UBOs in the UBO register. On this website, you can read more about the exceptions. Please note the strict deadlines: registration must take place within seven days of incorporation or amendment.

How do you register a UBO?

An authorised signatory of the organisation or a notary can register the UBO with the Chamber of Commerce. For trusts and similar arrangements, the administrator (trustee) is responsible.

What happens if you do not register UBO details correctly?

Firms are required to correctly register and update UBO details in the event of changes. If a firm fails to submit UBO information, submits it late, incompletely or incorrectly, this may result in legal consequences. It is therefore essential to ensure that UBO registration is accurate and kept up to date at all times.





 

 

Current developments

Access to the UBO register

On 22 November 2022, the Court of Justice of the European Union ruled that mandatory public access to UBO registers was insufficiently justified and infringed privacy rights. As a result, public access to the Dutch UBO register was suspended. For a period, access was limited to competent authorities such as law enforcement agencies and supervisory bodies, and Wwft institutions were required to request certified UBO extracts directly from clients.

Following legislative amendments, a new access regime entered into force on 16 July 2025. The UBO register is no longer publicly accessible to everyone; instead, access is restricted to specific categories of parties.

Access is currently granted to:

  • Competent authorities and public bodies, including supervisory authorities and Financial Intelligence Units (FIUs)
  • Obliged entities under anti-money laundering legislation (Wwft institutions), such as banks, notaries and other regulated professionals, for the purpose of customer due diligence
  • Natural and legal persons who can demonstrate a legitimate interest
  • UBOs seeking access to their own registered details

The concept of “legitimate interest” is further defined in secondary legislation and requires applicants to substantiate why access to UBO information is necessary.

The Dutch regime aligns with the forthcoming European Anti-Money Laundering Regulation (AMLR), which requires Member States to restrict access to UBO registers to parties with a legitimate interest rather than providing unrestricted public access.

 

Important: change to the UBO definition in 2027

When the AMLR enters into force in mid-2027, the definition of UBO will change. Under the AMLR, a natural person qualifies as a UBO with ownership or control of 25% or more, instead of more than 25%. Someone with exactly 25% ownership or control will therefore also be considered a UBO.

 

RegLab: your partner in AML compliance

Are you, as an AML institution, struggling with the obligations surrounding identifying UBOs and the UBO register? No need to worry. RegLab makes AML compliance considerably simpler. With guidance from our compliance specialists, we help you get on track. Would you like to know how we can support your firm? Please feel free to contact us.

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