In December 2019, the Parliament of Ukraine adopted a new law that substantially affects compliance obligations for Ukrainian legal entities regarding disclosure of information on ultimate beneficial owners (UBO) and ownership structure. The new obligations for Ukrainian legal entities, which go into force on 28 April 2020, include the following.

Notification for changes to UBO and ownership structure:

  • any changes of information on the UBO and ownership structure must be reported to a state registrar within 30 business days from their occurrence.

Update or confirmation of information on the UBO and ownership structure:

  • information on the UBO and ownership structure must be updated simultaneously with any registration application to a state registrar, or a confirmation should be provided on the absence of any changes of previously submitted information regarding the UBO and ownership structure.

Annual confirmation of UBO and ownership structure:

  • information on the UBO and ownership structure must be confirmed annually within 14 calendar days from each anniversary of the company’s registration date by submitting a set of documents to a state registrar including: the group ownership structure, an apostilled extract from a foreign register for a non-resident shareholder, and a certified copy of the UBO’s identification document.

First-time reporting:

  • already existing legal entities must submit information and documents on the UBO as outlined above and the ownership structure within three months following the implementation of the requirements. (The latter is expected to take place before 28 July 2020).

  • beginning 28 April 2020, information and documents on the UBO and ownership structure of newly registered legal entities must be submitted during the registration procedure for these entities.

Failure to notify or late notification to state authorities about the information on the UBO or changes to it can result in fines of between UAH 17,000 and UAH 51,000 (EUR 625 and EUR 1,875). The fine will be applied personally to the director of the company or to an authorised person.