UBO Register in Belgium: Obligations, Declaration and Penalties

What is the UBO register?

The UBO register (Ultimate Beneficial Owner) lists the natural persons who ultimately own or control a Belgian legal entity. It stems from anti-money-laundering legislation (EU directives) and is managed by the FPS Finance.

Every Belgian company, non-profit (ASBL), foundation or association must declare its beneficial owners there.

Who is a beneficial owner?

For a company, beneficial owners are the natural persons who:

• hold more than 25% of the shares or voting rights, directly or indirectly;
• or control the company by other means;
• failing that, the senior managers (directors, managers).

For a non-profit or foundation, these are the directors, the persons in charge of day-to-day management, the founders and the beneficiaries.

How to declare in the UBO register?

The declaration is made online and free of charge, via the "UBO Register" application on the FPS Finance MyMinfin platform. You log in with your eID or itsme.

What deadlines apply?

• First declaration: within one month of the entity's registration with the CBE.
• Update: within one month of any change (new shareholder, share transfer…).
• Annual confirmation: at least once a year, you must confirm the information is up to date.

What penalties apply?

A missing or inaccurate declaration exposes you to administrative fines of €250 to €50,000, plus possible criminal penalties. Obliged entities (banks, notaries) also check the UBO beforehand: a missing declaration can block opening an account or a notarial transaction.

Who can consult the UBO register?

• Competent authorities (tax, justice, anti-money-laundering unit);
• Obliged entities (banks, notaries, accountants) as part of their due diligence;
• Public access is now framed and subject to demonstrating a legitimate interest.

Conclusion

The UBO register is an unavoidable and recurring obligation: don't forget it after incorporation, and remember the annual confirmation. Incorrect information can have concrete consequences for your business.

Need help with your UBO declaration or compliance obligations? LegalBelgique handles your formalities and keeps track of your deadlines.