UBO register: do you have to register, and how do you do it?

Which legal forms must register?

The obligation applies to legal entities and partnerships. For entrepreneurs the BV, the general partnership (vof), the limited partnership (cv) and the professional partnership (maatschap) matter most. Foundations and most associations must also register UBOs. A sole proprietorship falls outside it: the owner is already visible in the Business Register, so a separate UBO register adds nothing.

Who is a UBO?

In a BV, a UBO is anyone who directly or indirectly holds more than 25 per cent of the shares or voting rights, or has actual control in another way. If you have a holding company with an operating company below it, you as shareholder of the holding are also UBO of the operating company, because you own those shares indirectly.

In a general or professional partnership, a UBO is anyone with more than 25 per cent of the ownership interest or who receives more than 25 per cent of the profit. Two partners who share everything fifty-fifty are therefore both UBOs. If nobody is above 25 per cent, for example with five equal partners, the directors or managing partners are registered as pseudo-UBOs.

How to file

Filing is free and goes through the Chamber of Commerce website. You log in with eHerkenning on behalf of the organisation; for a BV you need that anyway for your tax returns, see applying for eHerkenning. For a general partnership a paper form is also possible.

For each UBO you provide, among other things, the name, date of birth, nationality, home address and citizen service number, plus the nature and size of the interest, for example more than 25 up to and including 50 per cent. You must also upload a document showing that interest, such as the shareholders' register or your partnership agreement.

1. Determine who is a UBO, directly and through a holding.
2. Have the shareholders' register or partnership agreement ready.
3. Log in with eHerkenning and complete the UBO filing form.
4. Then check the confirmation and keep it in your records.

Who can see your details?

Until the end of 2022 anyone could request part of the UBO data for a fee. After a ruling by the European Court of Justice that stopped. Now only competent authorities, such as the financial intelligence unit and the tax authorities, and institutions with a statutory duty to check, such as banks, accountants and notaries, have access. Since 1 April 2026 those institutions can request a digitally certified UBO extract.

That explains why your bank asks about your UBO registration when you open a business account. If it is missing, or does not match what the bank sees itself, opening the account can stall. An institution that finds a discrepancy must also report it to the Chamber of Commerce.

Changes and enforcement

If something changes, for example because a partner joins, sells shares or moves house, you report it within one week. Many entrepreneurs forget this, because the change already seems settled at the notary or in the partnership agreement.

Not registering, or registering late, is an economic offence. Since 1 January 2026 a policy rule for enforcement applies, so a fine is no longer a theoretical risk. In addition, as director of a BV you are responsible for a correct registration; see also director's liability.

Frequently asked questions