The UBO register is launched today and the deadline for filing the relevant information therein has been postponed to 31 March 2019.

As we already informed you in an earlier article on our website, a register of ultimate beneficial owners, also known as the UBO register, was set up as a central register managed by the Ministry of Finance.

The UBO register is online as of today, 28 September 2018. All companies and legal entities that must comply with the obligations relating to the UBO register can log in.

Since the Royal Decree clarifying the operating conditions of the UBO Register is effective on 31 October 2018, the directors have until 30 November 2018 to register all known information about the ultimate beneficiaries of the company.

But that has changed. The website of the Ministry of Finance mentioned already in a FAQ that they grant an additional period until 31 March 2019. This is confirmed today by a press release from the Federal Government.

We suppose that we may assume that the final date for filing the relevant information has been postponed to 31 March 2019.

We repeat that it is crucial to take the necessary measures in good time, to collect the correct data about the right persons and to have them registered in the UBO register, taking into account the severity of the punishments.

It is also important that you work out procedures within your organisation to change the details of your final beneficiaries, which have to be sent to the UBO register within one month, as well as to work out a way in which the documents that prove that the information you provided is sufficient, accurate and up-to-date will be collected.