Introduction of the UBO Register in the Netherlands

On 27 September 2020, a UBO register will be introduced in the Netherlands. The introduction of the UBO register is based on the implementation act pursuant to which the EU Fourth and Fifth Anti Money Laundering (AML) Directives are transposed into Dutch legislation (the Implementation Act).

Under the Implementation Act, the ultimate beneficial owners (UBOs) of most entities formed or existing under Dutch law must be registered in the UBO register. Existing entities will be subject to a transitional period of 18 months from 27 September 2020, within which they must comply with the obligation to register their UBOs. However, new entities formed on or after 27 September 2020 will be obliged to do so immediately. More detailed information on the UBO Register in the Netherlands is set out in our memo on the introduction of a UBO register in the Netherlands.

According to the Implementation Act, the entities themselves are responsible for registering their UBOs and for keeping the registration up-to-date. Having said that, Heussen can advise on the specific registration requirements for any Dutch entity and can assist with the registration of UBOs in the UBO register on behalf of these entities.

For more information, please contact:

Juliëtte L.C. Schueler (
Tim B. Schreuders (
Martijn B. Koot (