In late August, we informed you of the Royal Decree of 30 July 2018 implementing the UBO register in Belgium (“Royal Decree”). Although the Royal Decree will enter into force on 31 October 2018, the Federal Public Service for Finance announced last week on its website that Belgian obliged entities, i.e. those required to disclose their UBO(s), now have until 31 March 2019 to submit information to the UBO register (the initial deadline was 31 November 2018).

Since 27 September 2018, it has been possible to access the UBO register using the MyMinFin application, meaning Belgian obliged entities can already start registering their UBO(s).

In this respect, an FAQ (available in French and Dutch) explaining inter alia how to connect to the application and identify an indirect UBO has been posted on the Federal Public Service for Finance website.

However, certain technical conditions regarding access to the UBO register still need to be clarified by ministerial decree. A user guide containing more detailed guidelines is expected by the end of this year.