in the questionnaire there is a request for the UBO where is that answer in my file
UBO data come from the Trade Register file, not from the UBO register
The answer is in the chain file, under the UBO structure that was established earlier in the first questionnaire where it appeared. It contains the names of the ultimate beneficial owners, their percentage of ownership or voting rights, and the nature of the interest. The system recognizes the UBO question in the new list and proposes the same answer; you confirm with yes or no and submit it yourself.
Note the difference with the official UBO register at the Chamber of Commerce: that is the statutory registration based on the Act on Prevention of Money Laundering and Financing of Terrorism, with its own update obligation. The chain file is not a replacement for it, but a copy of the last confirmed data for use in customer questionnaires. If the structure is no longer correct — a share sold, a new director — you first update that in the file via the UBO structure of the undertaking, so that the new questionnaire receives the correct answer instead of the old one. If the customer specifically asks whether someone in the structure holds a politically prominent position, that is a separate answer, to be found at the PEP status of directors and beneficial owners.
Legal basis: Trade Register Act alongside client due diligence under the AMLFT
The data linked to an undertaking — including directors and ownership structure — follow from the registration requirement of the Trade Register Act 2007. The question about the UBO itself usually does not come to the customer from that act, but from his own obligation to conduct client due diligence under the Act on Prevention of Money Laundering and Financing of Terrorism: banks and sometimes also larger trading partners need to know who is behind their counterparty. That is why almost every bank asks the same type of question, even though the portal looks different each time — see also why bank and insurer questions differ despite the subject.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- Act on the prevention of money laundering and the financing of terrorism — client due diligence
- Directive (EU) 2022/2464 (CSRD)
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.