Update: The implementation of the UBO register in other EU countries

24 October 2017

UBO register in the Netherlands
In March 2017, in the context of the implementation of the European forth anti-money laundering directive, the Netherlands submitted for consultation the draft legislative proposal which relates to the UBO register. The purpose of the UBO register is to register the relevant data of ultimate beneficial owners of companies and legal persons incorporated in the Netherlands. Under this European directive, on 26 June 2017 at the latest all EU member states must introduce the UBO register for entities that are incorporated within their territory. The Netherlands, however, did not meet this target date. According to State Secretary Wiebes, the draft legislative proposal on the introduction of the UBO register will be submitted to the House of Representatives at the beginning of 2018, and efforts are to introduce this register ultimately in the summer of 2018.

UBO register in other EU countries
Other EU countries are currently working as well on the implementation of the UBO register. Only Denmark, Germany and the United Kingdom met the target date to introduce the UBO register on 26 June 2017 at the latest. The other EU countries introduced the UBO register after the target date or are presently dealing with the legislative process that enables the introduction of the register.

Below please find a list of the progress that has been made in some of the EU countries on introducing the UBO register and how they have regulated or will regulate the access to the register.

EU Member State Introduced as of today Entry into force Access Who
The Netherlands no unknown public anyone
Belgium no unknown unknown unknown
Denmark yes 23 May 2017 public anyone
Germany yes 26 June 2017 not public certain authorities, authorities obliged to notify and persons/organisations with a legitimate interest
Finland no 1 January 2019 public anyone
France yes 1 August 2017 not public certain authorities, authorities obliged to notify and persons/organisations with a legitimate interest
Ireland no unknown unknown unknown
Italy no Next 12 months not public certain authorities, including public authorities, certain authorities and under conditions persons/organisations with a legitimate interest
Luxembourg no unknown unknown unknown
Austria no 2 May 2018 Not public certain authorities, authorities obliged to notify and persons/organisations with a legitimate interest
Portugal no unknown unknown anyone
Spain no unknown unknown unknown
United Kingdom yes 6 April 2016 public anyone
Sweden yes 1 August 2017 not public certain authorities, authorities obliged to notify and persons/organisations with a legitimate interest

If you have questions as a result of this article, please contact Mr mr. drs. R.X.J. (Xander) Blokzijl.