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Who is considered a UBO in Belgium?

Any individual who directly or indirectly owns more than 25% of shares or voting rights, or who exercises control by other means (e.g. appointment rights). If no such person exists, the senior managing officials (directors) must be declared.

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Which entities must register UBOs?

All Belgian legal entities including companies, non-profits, foundations, and certain trusts or similar structures.

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When must UBOs be declared or updated?

- Within 1 month of incorporation or any change in ownership or control.
- A mandatory annual confirmation must also be filed, even if nothing has changed.

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What supporting documents are required?

To justify the declared UBOs, the following documents may be required:

- Copy of the UBO’s identity card or passport
- Shareholder register or other proof of ownership
- Articles of association
- Documents for intermediary entities
- Company structure chart
- Voting or shareholder agreements
- Director appointment documents

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The exact documentation required depends on the entity’s structure and the type of UBO being declared.​​

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What are the risks of getting it wrong?

Incorrect or incomplete UBO information may result in:

- Administrative fines ranging from 250 € to 50,000 €
- Reputational and legal risks
- Delays in bank onboarding, investor compliance, and audits

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Need assistance?

 

Determining the correct UBOs and preparing the required supporting documents can be complex, especially in multi-layered or international structures.

We assist with:

- Analysing ownership and control

- Identifying the correct UBOs (direct and indirect)
- Preparing the documentation required for the register
- Completing the electronic filing and ensuring timely updates

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This ensures full compliance with Belgian UBO regulations and reduces the risk of delays or administrative penalties.