who do I enter as ubo in esg or customer questionnaire

Natural persons, not the holding above

The UBO you enter is the natural person who ultimately owns or controls the enterprise — never an intermediary holding or the parent company itself. For a private limited company, this generally applies to: anyone with more than 25% of the shares, voting rights or economic interest, directly or indirectly. If there is no single natural person above that threshold, the statutory director is deemed to be the UBO — this is called the pseudo-UBO. This is the answer you also enter in an ESG or customer questionnaire: the same persons as in the UBO register, not a customized version for the occasion.

If you are uncertain about the governance structure — a foundation above the private limited company, a trust, dispersed shareholding just under the 25% per person but jointly above it — then that is precisely the kind of question where separate legal advice is more prudent than a quick assessment. If you enter this with a customer who also asks about your board, the same list often includes the question how your board is composed; these are two separate questions with a partly overlapping source, namely your own UBO register and Chamber of Commerce extract.

Where this stems from: customer due diligence under the AMLD

The obligation to identify the UBO does not come from an ESG standard, but from the Anti-Money Laundering Directive: banks and other AMLD-regulated institutions must, as part of customer due diligence, establish who the ultimate beneficial owners of their client are. Customers who are not themselves AMLD-regulated — a manufacturer that collects ESG data from suppliers — often request the same information anyway, because they need it elsewhere in the supply chain or simply want to know who they are doing business with. EFRAG VSME itself does not prescribe a UBO definition; the basic module asks about governance structure, not about shareholders. Those who prefer not to enter the names of their UBOs in an external portal can use Supplia's confidentiality button per answer — this does not change what you enter, but does change who can see it.