The Royal Decree on the operating modalities of the UBO register (amended on 23 September 2020) requires information providers (i.e. companies, associations, foundations, trusts, etc.) to confirm annually the accuracy of the information on their ultimate beneficial owners (« UBO »). For technical reasons related to the online platform, the information on beneficial owners of all information providers was automatically confirmed by the FPS Finances on 30 April 2020.
By 31 August 2021 at the latest (i.e. deadline of 30 April 2021 having been postponed to this date), the parties responsible for providing information must therefore reconfirm that the information on their ultimate beneficial owners is correct and up to date. As a reminder, the parties responsible for providing information must also communicate - within one month - any change in the information on the beneficial owners (cf. article 1:35 of the Companies and Associations Code).
It is also worth recalling that since 11 October 2020, information providers are required to provide "any document demonstrating that the information relating to a beneficial owner is adequate, accurate and up-to-date". Legal representatives must therefore provide proof of the accuracy of the information relating to the identity, nature and extent of the beneficial owner's interest in the information provider.
By 31 August 2021 at the latest (i.e. deadline of 30 April 2021 having been also postponed to this date), information providers - having already registered their beneficial owners in the UBO register before 11 October 2020 - must comply with this new requirement to provide supporting documents.
Therefore, please ensure that you complete the above formalities before 31 August 2021. If applicable, the directors of the information providers may be subject to administrative fines of between EUR 250 and EUR 50,000. Please visit your MyMinfin portal soon.
