Who are the ultimate beneficial owners of the company?

Natural persons with an interest or control exceeding 25%

UBOs (ultimate beneficial owners) are the natural persons who actually own or control the enterprise: more than 25% of the shares, more than 25% of the voting rights, or actual control through another means. In the case of a private company (BV), these are usually the shareholders above that threshold; in the case of a foundation or association, they are board members or others with comparable actual power. If there is no one who meets that criterion, then the senior management — statutory board — qualifies as UBO. This is therefore not a question about the statutory name or address of the enterprise itself; the client asks for those identity details separately, see what the client means by statutory name.

The client almost always asks this together with a follow-up question: whether one of those persons is a PEP, a politically exposed person. That is a separate test with its own consequences for client due diligence, separate from the question of who the UBOs are — see what the client means by UBO and PEP. For the answer to the UBO question itself, the shareholder register or the UBO register at the Chamber of Commerce is usually the supporting document. If a current register is missing, or if the control structure has just changed, then this is a question to confirm yourself rather than have automatically filled in.

Basis: client due diligence under the Wwft

This question does not come from a sustainability or cyber checklist, but from the client due diligence that banks, insurers and sometimes also larger trading partners are required to carry out under the Act on the Prevention of Money Laundering and the Financing of Terrorism. That act requires the institution sending the questionnaire to establish and verify the identity of the UBO before it enters into or continues a business relationship. The question thus does not come from the supplier, but follows directly from a legal obligation of the client itself.