The much anticipated UBO register is expected to become operational on 10 January 2020. The UBO register will be kept by the Netherlands Chamber of Commerce and will be separate from the Dutch Trade Register. All legal entities registered in the Netherlands, including foundations, must ensure that their ultimate beneficial owners (UBO) are entered into the UBO register. Listed companies incorporated in the Netherlands are exempt from registering their UBO in the register, and the Dutch Minister of Finance recently confirmed that their 100% direct or indirect Dutch subsidiaries are also exempt from the UBO registration requirements. Both groups of exempt companies may have to apply for this exemption. Other subsidiaries or group companies are not exempt.

As of the start date of the UBO register, all newly incorporated legal entities must register their UBO when they first register with the Dutch Trade Register. Existing legal entities must register their UBO in the UBO register by the end of June 2021.

If you have any questions, contact Birgit Snijder at our AML practice group.