From September 27, 2020, the UBOs of Dutch companies and other legal entities must be registered in the UBO register of the Chamber of Commerce.Existing entities have 18 months to register the UBOs. They will receive a letter from the Chamber of Commerce for this in the near future. The Chamber of Commerce sends the letters dosed so that it has time to process all registrations. The first letters have already been sent. The letter from the Chamber of Commerce may raise questions for you. The most frequently asked questions about UBO registration for existing entities can be found below:
The letter states that the entity must register the UBO within 6 weeks. What if this is not done in time?
Although existing entities have 18 months (to be calculated from 27 September 2020) to provide the UBO declaration, the Chamber of Commerce requests that the UBO(s) be registered within 6 weeks. This is therefore a request from the Chamber of Commerce and not a legal obligation.
What is required for a UBO registration?
- DigiD;
- IBAN (account number) in the name of the authorized signatory, for making a 1 eurocent payment;
- data of UBO(s);
- copy of a valid ID of the UBO(s);
- copies of documents showing that someone is a UBO (register of shareholders, articles of association, register of depositary receipts, deed of incorporation, other notarial deed, deed of partnership / CV, structure chart, etc.).
Is there a PDF form available with which to register?
The web forms of the Chamber of Commerce must be used to register a UBO. PDF forms are available, but at the moment the starting point is that the Chamber of Commerce will only handle these in complex cases for which the web form is not sufficient. The Chamber of Commerce must first give its permission to use a PDF form. Note. The web form cannot be saved and must therefore be completed correctly in one go.
Are there conditions attached to the use of the web module used by the Chamber of Commerce?
The person authorized to sign must log in with his or her DigiD and pay 1 cent via iDeal to be able to submit a digital statement.
What to do if the person authorized to sign does not have a DigiD?
Registration can be done by a notary. The PDF forms can be used in consultation with the Chamber of Commerce.
How do I know which information I must provide to support the UBO designation?
Visit www.kvk.nl/ubo. There is also a step-by-step plan available to determine the UBO. The Chamber of Commerce has no advisory role in this. If you still have questions after reading the step-by-step plan, you can contact one of our specialists.
How long does it take for the Chamber of Commerce to process my UBO statement in the UBO register?
The Chamber of Commerce states that it takes a maximum of one month for the statement to be processed in the UBO register. The organization and the UBO(s) receive a message after the information has been processed. A UBO statement via the civil-law notary is processed in the UBO register within 3 hours.
How do I report a change to my existing UBO registration?
Changes can be made by the civil-law notary or by the authorized signatory of an entity using the web module.
Do you need help? Please contact us!
If you have any questions or need help with collecting documents, determining the UBO(s) and preparing the forms, please fill in the attached form or contact Eline van Elst or Renate Baken directly.
