Introduction of UBO register in the Netherlands

On 27 September 2020, a UBO register was 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 have 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. New entities formed since 27 September 2020 are already obliged to register their UBOs. Existing entities, however, are subject to a transitional period of 18 months ending on 27 March 2022, within which period they must comply with the statutory obligation to register their UBOs. Non-compliance may be subject to administrative and/or criminal sanctions. 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. Heussen can, however, 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.

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