UBO register Netherlands: registration and access

Almost every Dutch legal entity and partnership must register its ultimate beneficial owners (UBOs) in the UBO register of the Chamber of Commerce (Kamer van Koophandel, KVK), and must report any change within one week. The main exceptions are sole proprietorships, listed companies and their wholly owned subsidiaries, and owners’ associations (VvE).

Since 1 January 2026 the Dienst Financieel-Economische Integriteit (DFEI) can fine an entity up to €27,500 for a missing, incorrect or incomplete UBO registration. Below we explain who counts as a UBO, how you register, who can see the data and what changes in 2027.

Table of contents

What is the UBO register?

It is a part of the Dutch trade register (handelsregister) in which entities record the natural persons who ultimately own or control them. It was introduced to implement the EU anti-money laundering directives and has been operational since 27 September 2020. See also the definition of the UBO register in our legal glossary.

The register sits alongside the customer due diligence that banks, notaries, accountants and other Wwft institutions must carry out under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft). Those institutions identify the UBO themselves and use the register as a source.

Which entities must register UBOs?

private and public limited companies (BV and NV), including European companies (SE);
foundations (stichting) and associations with full legal capacity (vereniging);
cooperatives and mutual insurance associations;
general partnerships (vof), limited partnerships (cv), professional partnerships (maatschap) and shipping partnerships (rederij).

Exempt are sole proprietorships (eenmanszaak), companies listed on a regulated market and their wholly owned subsidiaries, owners’ associations (VvE) and public-law legal entities. Trusts and similar legal arrangements have their own register.

Who counts as a UBO?

A UBO is a natural person who directly or indirectly holds more than 25 per cent of the shares, voting rights or ownership interest, or who has control by other means, for example through a shareholders’ agreement or a veto right.

In a BV or NV: a person with more than 25 per cent of the shares or votes, also through intermediate holding companies.
In a foundation or association: a person who can exercise more than 25 per cent of the votes on an amendment of the articles, or who has actual control.
In a partnership: a person entitled to more than 25 per cent of the ownership interest or the profit, or who can block decisions.

If no one meets these criteria, or if there is doubt, the senior managing officials count as UBOs, usually the statutory directors or partners. These are known as pseudo-UBOs.

What information do you register?

Name, date of birth, nationality, country of residence, and the nature and extent of the interest, for example “ownership interest of 50 to 75 per cent”. You also provide supporting documents, such as a shareholders’ register or a structure chart, and the citizen service number (BSN) or foreign tax number.

The KVK checks that the report is complete, but does not decide who the UBO is. The entity, acting through its directors, remains responsible for the accuracy of the data. Keep a record of how you determined the UBO, because the DFEI may ask for it.

How and when do you register?

A new BV, NV, foundation or cooperative is incorporated by notarial deed, and the notary usually registers the UBO at the same time. Partnerships and associations register the UBO themselves when registering with the KVK.

A change must be reported within one week. Think of a share transfer above or below 25 per cent, a new director who becomes a pseudo-UBO, or a UBO who moves abroad. A director who signs for the entity can submit the change online with eHerkenning or by form.

Who can see the UBO data?

Since the judgment of the Court of Justice of the European Union of 22 November 2022 (joined cases C-37/20 and C-601/20, WM and Sovim), the public no longer has access. The court held that general public access to UBO data is a disproportionate interference with privacy.

The Act restricting access to the UBO registers (Staatsblad 2025, 189) limits access to four groups: competent authorities, the financial intelligence unit, Wwft institutions and persons with a legitimate interest; parties that need it for sanctions compliance; public bodies that need it for a public task; and the registered persons for their own data. Access for persons with a legitimate interest is regulated by a separate decree, a draft of which was sent to the Senate on 2 April 2026.

In the meantime, an entity can request a certified UBO extract itself through the KVK and share it with its bank or notary. A UBO who runs a demonstrable risk, for example because of police protection, can ask for the data to be shielded.

What are the consequences of not registering?

Failing to register, registering incorrectly or registering incompletely is an economic offence. Since 1 January 2026 the DFEI applies a fining policy for administrative fines with a maximum of a fourth-category fine, currently €27,500.

The DFEI does not start at the maximum. A first violation is fined at 10 per cent (€2,750), rising to 20, 40, 80 and finally 100 per cent for repeat violations within five years. In special cases it can impose an order subject to a penalty payment instead.

The practical consequences are often greater. Banks, notaries and payment service providers cannot complete their customer due diligence without correct UBO data, so an account opening, financing or share transfer may stall.

What changes in 2027?

The EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624, AMLR) applies to most of its provisions from 10 July 2027. It lowers the ownership threshold from “more than 25 per cent” to “25 per cent or more” and harmonises the UBO definition across the EU. Entities with a shareholder at exactly 25 per cent should check their registration before that date.

What should you check as a company?

Map the full ownership chain up to the natural persons, including holding companies and trusts.
Check shareholders’ agreements and articles for veto rights or other forms of control.
Register a pseudo-UBO if no one meets the 25 per cent threshold.
Report every change within one week, including a change of director.
Keep a file showing how the UBO was determined, for the DFEI and your bank.

What should you check as a UBO?

Check through the KVK which data is registered about you.
Ask the entity to correct incorrect data on the nature and extent of your interest.
Consider a shielding request if you run a demonstrable security risk.
Expect questions from banks and notaries about the source of your funds.

What can we do for you with the UBO register?

Determine who the UBO is in complex structures with holding companies, trusts or foundations.
Prepare the registration and supporting documents for the KVK.
Assess the effect of a share transfer or shareholders’ agreement on the UBO registration.
Respond to questions or a proposed fine from the DFEI.
Advise on Wwft due diligence by your bank or notary. See also our page on corporate law.

Summary

Almost all Dutch entities and partnerships must register their UBOs with the KVK; sole proprietorships and listed companies are exempt.
A UBO holds more than 25 per cent or has control by other means; otherwise the senior managers are pseudo-UBOs.
Changes must be reported within one week.
The public has had no access since 22 November 2022; access is limited to authorities, Wwft institutions and persons with a legitimate interest.
Since 1 January 2026 the DFEI can impose fines of up to €27,500.

Frequently asked questions

Do I need to register a UBO for a holding BV that I own alone?

Yes. You are the UBO of the holding company, and of every subsidiary in which the holding company has more than 25 per cent. Each entity files its own UBO report.

Is a director automatically a UBO?

No. A director is only registered as a pseudo-UBO if no natural person meets the ownership or control criteria, or if the UBO cannot be determined.

Can I see who the UBOs of my business partner are?

Not directly. Since 2022 the register is not public. You can ask your business partner for a certified UBO extract, or rely on the due diligence of your bank or notary.