Can I arrange the UBO registration myself?
In many cases you can handle the UBO registration yourself via the Business Register of the Chamber of Commerce. UBO stands for Ultimate Beneficial Owner, the ultimate beneficial owner: the person who is directly or indirectly the owner of an organisation or has control over it. With a simple structure, for example one company with one or two shareholders who are also directors, registration is usually a matter of filling in data and uploading documents.
With more complex structures, such as holding companies, foreign shareholders, trusts or multiple layers between the enterprise and the ultimate owner, it becomes more difficult to determine yourself who exactly should be listed as UBO. In those situations entrepreneurs often engage a notary or legal advisor, although no rule requires this to be mandatory.
What a UBO registration involves exactly
The UBO registration is part of the Business Register and is intended to make it clear who is behind an organisation. This is relevant in combating money laundering and the financing of criminal activities. Some of the data is public, other data is only accessible to competent authorities such as banks, the Tax Administration and supervisory bodies. Which data is exactly public and which remains shielded may change from time to time; you will find the current status on the website of the Chamber of Commerce.
When you can do it yourself
With a sole proprietorship or a private company with a clear ownership structure, self-registration is straightforward. You will then need your Chamber of Commerce registration, a valid identity document of the UBOs and sometimes an extract of the shareholding structure. The Chamber of Commerce website guides you step by step through the process. If you are unsure whether your structure is simple enough to register yourself, it does no harm to write this down first before you start.
When a notary or advisor makes sense
As soon as there is uncertainty about who exactly qualifies as ultimate beneficial owner, for example with family businesses with multiple generations, with international structures or with organisations without clear shareholders such as foundations, determining the UBO becomes a substantive question. A notary who has guided the incorporation or amendment of articles often already knows the structure and can help in determining it correctly. For the legal interpretation of your specific situation, a notary or legal advisor is and remains the appropriate point of contact.
Why your customer asks for UBO information
Banks and insurers request UBO information as part of customer due diligence, often referred to as KYB: Know Your Business. Increasingly, business customers are also asking for it, as part of their own supply chain due diligence. They want to know who they are doing business with and whether there are signals that warrant extra attention. This is a different process from certification or assessment: checking and recording takes place, not approval in the sense of a quality mark.
Because UBO data are often requested together with other evidence, such as extracts, statements and policy documents, it is useful to know exactly what is being asked and what is already registered with the Chamber of Commerce. In the knowledge base sorted by subject you will find an overview of which concepts belong to which questionnaire and where they come from.
What you do and do not need to share
Not every customer is entitled to the same level of detail in information. Some UBO data is public and can therefore be requested anyway; other data is not and is shared only if there is a concrete, justified reason for it. If you are unsure about what you should share with a specific customer, it is advisable to assess this against your own situation, possibly with a lawyer, rather than routinely sharing everything that is requested.
Keep track without having to look up everything again
The inconvenience of UBO and KYB questions is not the registration itself, but the fact that virtually every customer asks for it in their own way, with slightly different documents or forms. With a few questions you immediately see where you stand, without having to create an account first. If you want to know how supplia.eu goes about this and where the information comes from, you can read about it on the page that explains how it works.
If you have a concrete question about your own structure or a specific questionnaire after reading, you will find additional explanations in the frequently asked questions by entrepreneurs. For the legal assessment of your own situation, a notary, lawyer or the Chamber of Commerce remains the right point of contact; we do not explain, certify or assess anything, but we do help you find the right documents and answers in one place.
Do you want to see which questionnaires and concepts are relevant for your business before you spend time on them? Take the free quick scan or browse through the topics in the knowledge base, and you will know where you stand within half an hour.