Upload supporting documents in the UBO register: time until 31 August

In 2017, the UBO register (Ultimate Beneficial Owner) was introduced in Belgium, as in all other European member states. As a result, since 30 September 2019 you have to make certain information about the ultimate beneficial owner public. On 1 October 2020, a royal decree was published that sets additional requirements on the quality of that information. The deadline of that decision has been postponed from 30 April to 31 August 2021.

Purpose of UBO

The purpose of the UBO legislation is to find out who is behind a company in the context of anti-money laundering legislation. It prevents the use of screen companies.

The legislation was slightly adjusted in 2020. One of the amendments concerned the obligation for reporting agents which are a trust, fiduciary or similar legal arrangement to “provide any document that demonstrates that the information included in the register is adequate, accurate and up-to-date”. The rationale is that this will ensure the effectiveness of the authorized access. The reporting agent had until 30 April 2021 to include such supporting documents in the system.


Early April, the FPS Finance communicated that this deadline would be postponed to 31 August 2021. There are two reasons for this.

Firstly, the FAQ which can be consulted on the FPS Finance's website (https://finance.belgium.be/en/E-services/register-beneficial-owners) contained some uncertainties, a. o. items about the definition of the term “beneficiary” in some special situations and about the entities that do not have to register an UBO. It also further clarifies what information is visible to all users (for most of the information it must be demonstrated that you have an interest in accessing the information).

Secondly, the application is made more user-friendly. It will be easier to add documents, for example by establishing a direct link with publications in the Belgian Official Gazette. The database is also linked to the database “eStox” (the electronic share register of the Federation of Notaries) and to the database of the ITAA (Institute for Tax Advisors and Accountants). This makes it possible to link electronic share registers to the UBO.

As of 1 September 2021, sanctions are possible for legal entities (companies and associations) that have not uploaded the required information in the register.