From 27 September 2020, Dutch legal entities will be obliged to register their ultimate beneficial owners (UBOs) with the UBO register.

Existing Dutch entities are subject to a registration period of 18 months (i.e. until the end of March 2022). New Dutch entities incorporated as of 27 September 2020 will be obliged to register their UBOs when they first register with the trade register. This overview sets out which entities are obliged to register their UBOs and who shall be regarded as UBOs. Our newsletter of 23 June 2020 contains further information about the UBO register.

The act will enter into force in stages:

  • From 8 July 2020, all Dutch legal entities will be obliged to obtain information about their UBOs. Foundations are also obliged to keep an internal register of distributions.
  • From 27 September 2020, the above obligation to register UBO's will become effective.
  • On a date yet to be determined, rules will enter into force relating to the identification of persons who consult the UBO register and providing UBOs with insight into the number of times their information has been provided to third parties other than government parties.

We expect that in the near future more will be known about the way in which the registration of UBOs can take place (e.g. forms and guidance issued by the trade register).

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