Company

Ultimate beneficial owner

By the Finances Indépendants editorial teamUpdated on 2 min readAlso known as: UBO, Beneficial owner, UBO register, Bénéficiaire effectif

Contents
  1. Who is the ultimate beneficial owner?
  2. The UBO register
  3. Ongoing obligations
  4. What forgetting costs
  5. Not to be confused with
  6. Further reading
  7. Frequently asked questions
25%
Ownership or control threshold, in principleFPS Finance2026
1 month
Deadline to update after a changeFPS Finance2026
Annual
Mandatory confirmation of the dataFPS Finance2026
€50,000
Maximum administrative fineFPS Finance2026

Who is the ultimate beneficial owner?

It is the individual who, at the end of the ownership chain, actually owns or controls the company. The main criterion is holding, directly or indirectly, more than 25% of the shares or voting rights.

Control can also come about by other means: a shareholders' agreement, the right to appoint a majority of the directors, decisive de facto influence. A company in which no shareholder reaches the threshold names its directors as ultimate beneficial owners under the residual category.

The UBO register

The register is kept by FPS Finance and supports the fight against money laundering. The declaration is made online, by the company's legal representative or by an authorised agent, an accountant or lawyer.

The data declared include the beneficial owner's identity, the nature and extent of their interest, and the date on which they became one. Supporting documents must be attached: share register, articles of association, ownership chart.

Ongoing obligations

The initial declaration does not exhaust the obligation: it is keeping it up to date that causes problems in practice.

  • Declare within one month of the company being set up.
  • Update within one month of any change: transfer of shares, a shareholder joining or leaving, a change of director.
  • Confirm the data at least once a year, even if nothing has changed.
  • Keep the supporting documents that back up the declaration.

What forgetting costs

Administrative fines can reach €50,000, and criminal penalties apply in the most serious cases. A forgotten annual confirmation is the most common breach, because nothing reminds you of it.

Beyond the fine, a non-compliant declaration blocks certain steps in practice: opening an account, banking relationships, transactions before a notary. Bodies subject to due diligence obligations consult the register.

Not to be confused with

The terms close to Ultimate beneficial owner and what sets them apart.

Ultimate beneficial owner and the director
The director manages the company; the ultimate beneficial owner owns or controls it. The two often coincide in an SME, but not always: a salaried director without shares is not a beneficial owner on that basis.
Ultimate beneficial owner and the shareholder in the share register
The share register lists direct owners, including companies. The UBO register traces the chain up to the individuals.

Further reading

Ultimate beneficial owner: frequently asked questions

  • The individual who ultimately owns or controls a company, in principle above 25% of the shares or voting rights, directly or indirectly. Control can also come from an agreement or decisive de facto influence.

  • All Belgian companies, as well as non-profit associations (ASBL/VZW), foundations and trusts. The obligation depends neither on size nor on activity.

  • Within one month of any change: transfer of shares, a shareholder joining or leaving, a change of director. An annual confirmation of the data is also required, even if nothing has changed.

  • Administrative fines of up to €50,000, and criminal penalties in the most serious cases. A non-compliant declaration can also block banking or notarial procedures.

  • The company then declares its directors as ultimate beneficial owners, under the residual category. It is not possible to declare that there is no beneficial owner.

  • The company's legal representative, or an authorised agent, in practice the accountant or lawyer. Responsibility for its accuracy remains with the company.

Official source

  1. FPS Finance, UBO. View (new tab)(Official source, accessed on 2026-09-19)