UBO Register in the Netherlands: Who Must Register, Deadlines and Foreign Owners (2026)

In the Netherlands, most organisations, from an unlisted BV to a stichting or a VOF, must register their ultimate beneficial owners (UBOs) in the UBO register of the Chamber of Commerce (KVK). A UBO is the natural person who ultimately owns or controls the organisation, usually through more than 25% of the shares or votes. The register is not public: only the organisation, its UBOs, and authorities and institutions named by law can see the data.

This guide for international founders and foreign shareholders covers who is a UBO, who must register, the documents and deadlines, UBOs abroad, access and penalties.

In Short

• Who is a UBO: a natural person with more than 25% of the shares, votes or ownership interest, directly or indirectly, or with actual control. If nobody qualifies, the directors (or partners) are registered.
• Who registers: unlisted BVs and NVs, stichtingen, most verenigingen and partnerships. Not the eenmanszaak or listed companies.
• New entities: the UBOs are registered with the first registration, usually through the notary.
• Changes: within 7 days after they take effect.
• UBOs abroad: without a Dutch citizen service number (BSN), they are registered with the tax identification number (TIN) of their country of residence.
• Penalty: a fine of up to €27,500 or an order subject to a penalty.

Who Is a UBO?

A UBO is always a natural person: a company or other legal entity can never be one. The categories are set in article 3 of the Uitvoeringsbesluit Wwft 2018 and differ by legal form:

Legal form	A UBO is anyone with	If nobody qualifies
BV, NV, SE, SCE	More than 25% of the shares, votes or ownership interest, or actual control	Every statutory director
Stichting, vereniging, coöperatie	A right to more than 25% of the assets, more than 25% of the votes on amending the articles, or actual control	Every statutory director
VOF, CV, maatschap, rederij	A right to more than 25% of the assets, more than 25% of the votes on amending the partnership agreement, or actual control	Every partner, except limited partners

KVK asks you to check these interests in the order shown and to register each UBO with the first one that applies. For shares, votes or an ownership interest, you also give the band: more than 25% up to 50%, more than 50% up to 75%, or more than 75% up to 100%. Actual control means influence outside a formal role.

The directors are registered as “pseudo-UBOs” only if, after every possible means has been used and with no grounds for suspicion, nobody qualifies, or if there is doubt about the person found. Exactly 25% is not enough.

Which Organisations Must Register

The duty applies to organisations set up in the Netherlands. According to KVK:

• Must register: BVs, NVs, SEs and SCEs, unless listed; every stichting; verenigingen, except those with limited legal capacity and no business; coöperaties; VOFs, CVs, maatschappen and rederijen; and certain church bodies that KVK has written to.
• Do not register: the eenmanszaak (sole trader); listed BVs and NVs and their 100% subsidiaries, also further down the chain; owners’ associations (VvE); entities still in formation; and public-law bodies.

A foreign company, such as a UK Ltd or a German GmbH, registers its UBOs in its home country, even if it has a Dutch branch. A Dutch BV that it owns does register here. Trusts and similar arrangements, such as a fund for joint account (FGR), have a separate UBO register, in which the trustee registers.

What Is Registered and Which Documents You Need

For each UBO, the register holds (article 15a of the Handelsregisterwet 2007):

• name, date, place and country of birth, nationality, country of residence and home address;
• the BSN, if the person has one, or else the TIN and the country that issued it;
• the type and size of the interest, with copies of the documents that show the identity and the interest.

For each new UBO, KVK needs a colour copy, front and back, of a valid passport, identity card, Dutch driving licence or residence document. Any BSN on it must stay visible. Add documents showing the interest, such as the shareholder register or the articles of association, and an organisation chart for an indirect interest. No interest documents are needed for pseudo-UBOs, or for a registered sole shareholder who holds all the shares directly.

Deadlines

• New entity: the UBOs are registered with the first registration, at a KVK office or through the notary, not online. A legal entity must be registered within one week after it is formed.
• Changes: a change, such as a share transfer that takes someone above 25%, or down to 25% or less, must be reported within 7 days after it takes effect. The same applies when someone stops being a UBO.
• Existing entities: had to register by 27 March 2022. No extension is possible.

How to Register

The UBO report (UBO-opgave) is made by an authorised signatory, such as a director, or by a civil-law notary. KVK’s form is only in Dutch. Online, the signatory logs in with DigiD and uploads the documents. Without DigiD, for example when the director lives abroad, the report goes by post with printed copies of the UBOs’ IDs, the signatory’s own ID and the interest documents; send it by registered mail.

KVK checks that the report is complete, but it does not decide who the UBOs are: that is your responsibility, and your UBOs must give you the information. The organisation and each UBO receive a confirmation letter. Signatories can order a certified UBO extract in Mijn KVK for €3.10. See also why a BSN matters for non-resident directors and shareholders.

Foreign Shareholders and Ownership Chains

When a foreign company holds shares in the Dutch BV, you look through it to the natural persons behind it, wherever they live. The government’s general Wwft guideline gives the basic case: if a company owns 100% of the BV and two people each own 50% of that company, both hold 50% of the BV.

Dutch law says “directly or indirectly” but sets no formula for smaller stakes. The guideline looks at influence, level by level, and counts anyone who meets the 25% threshold in some way. So if you control a holding with 60% of its shares, and it has 40% of the votes in the Dutch BV, you decide those votes: expect to be registered, even though 60% of 40% is only 24%. Have such chains checked before you file.

Situation	Who is the UBO
You own 100% of a holding BV, which owns 100% of an operating BV	You, in both BVs (more than 75% up to 100%)
A UK Ltd owns 100% of the Dutch BV; two people each own 50% of the Ltd	Both people (more than 25% up to 50%)
Four shareholders each hold exactly 25%, with no other control	Every statutory director, as pseudo-UBO
Ten shareholders have agreed that one of them votes for all	That shareholder, through actual control
A stichting has three directors, each with one vote on amending the articles	All three (33.3% each)
Two partners share a VOF 50/50	Both partners

Who Can See the UBO Register?

Since a ruling of the EU Court of Justice on 22 November 2022 (joined cases C-37/20 and C-601/20), the register has not been public, and a Dutch act restricting access has applied since 16 July 2025. According to KVK:

Who	What they can see
You as a UBO, and the organisation	Your own registration, in Mijn KVK
Wwft institutions (such as banks, accountants and lawyers) for their client checks	Name, month and year of birth, country of residence, nationality, and the type and size of the interest
The Financial Intelligence Unit, supervisors, the Tax Administration, police, prosecutors, civil-law notaries and other designated public bodies	All data, including the BSN or TIN and the address
The general public	Nothing

Since 1 April 2026, KVK has been reopening access in stages, starting with notaries and banks; until their sector has access, institutions ask their clients for a certified extract. Access for people with a legitimate interest, such as journalists, is not open yet: KVK reports that the rules are still being prepared.

Discrepancy Reports

Banks, accountants, notaries and other Wwft institutions may not rely on the register alone. If their client research shows a missing UBO, a wrongly registered person or a wrong interest, they must report it to KVK. KVK then decides whether the data must change, a decision you can challenge by objection and appeal, and passes missing or incorrect registrations to DFEI, the Ministry of Finance’s enforcement service.

Fines and Other Consequences

• Fine or penalty order: DFEI can impose a fine of up to €27,500, or an order subject to a penalty with no maximum, for a missing, incorrect or incomplete registration.
• Economic offence: failing to register is also an offence under the Economic Offences Act, punishable by up to six months’ detention, community service or a fine of up to €27,500; for a legal entity, a court can go up to €110,000 if that amount is not an appropriate punishment.
• In practice: a bank must check that a new Dutch client’s UBOs are registered, so a missing registration can delay an account. Giving your UBOs to the bank is not enough.

DFEI usually writes first: after two reminders from KVK, an organisation gets a letter and has 3 weeks to register, or to deregister it if it is no longer active (DFEI, in Dutch).

What Changes in July 2027

The EU Anti-Money Laundering Regulation (EU) 2024/1624 applies from 10 July 2027. It sets the threshold at 25% or more, multiplies percentages along ownership chains while also looking at who controls each company in the chain, and allows up to 28 calendar days to report changes. DFEI says the exemption for listed companies will change too. Until then, the rules above apply.

How NetherBridge Partners Helps

Our company secretarial services cover UBO registration and updates: we collect the ownership and control information, review whether a share transfer or other corporate event changes the registered UBO position, and coordinate the report with KVK or the notary. For a new company, the UBO step is part of our Dutch BV formation support. Contact us to have your structure checked.

The rules in this article were checked in November 2026 against KVK, DFEI, business.gov.nl, Ondernemersplein, the Handelsregisterwet, the Wwft and their decrees, the government’s Wwft guideline and EUR-Lex.

Frequently Asked Questions