The UBO (Ultimate Beneficial Owner) register names individuals with a >25% interest in your BV. Filing happens at incorporation, within the KvK process; updates within 7 days of any change. Since the 22 November 2022 CJEU ruling, the register is no longer publicly searchable: access is restricted to competent authorities and AML-obliged parties.
What is a UBO?
A UBO is any natural person who, directly or indirectly, sits behind the legal entity. For a Dutch BV the statutory tests are deliberately broad. A person is a UBO if they hold more than 25% of the shares, hold more than 25% of the voting rights, or otherwise exercise effective control, for example through a shareholder agreement, golden share, or the practical ability to appoint and dismiss directors.
- Holds >25% of the shares, or
- Holds >25% of the voting rights, or
- Otherwise exercises effective control over the BV.
The point of the regime is to identify the real human being who ultimately benefits from or controls the company, behind any chain of corporate ownership. If no such person can be identified, because ownership is genuinely diffuse, the BV's statutory directors are registered as "pseudo-UBOs" instead (more on that below). There is always at least one UBO on file: the register is never simply left blank.
What gets disclosed
It helps to separate two things that the spec deliberately keeps apart: the data the KvK holds about each UBO, and the narrower set of data that authorised parties can actually see. The disclosed fields are deliberately limited; the most sensitive identifiers are held but never shown.
| Visible to authorised parties | Held but not disclosed |
|---|---|
| Full name | Full date of birth |
| Month and year of birth | Place of birth |
| Nationality | Residential address |
| Country of residence | ID document number |
| Nature & extent of interest (in bands) |
The "nature and extent of the beneficial interest" is never published as an exact percentage. It is shown in 25% bands only: >25%, >50% or >75%. So an authorised viewer learns that you hold, say, more than half of the BV, but not whether that is 51% or 90%. Your full date of birth, place of birth, residential street address and passport number are all collected for verification but sit in the non-disclosed layer.
Filing timeline
The UBO filing is woven into the formation itself, not a separate later chore. There are three moments to keep in mind.
- At incorporation: the notary files the initial UBO data alongside the KvK registration. We handle this in every formation package, so there is nothing extra for you to file on day one.
- On any change: you have 7 days to update the register after a change in ownership or control. This is a short window and easy to miss, which is why it is worth treating any cap-table change as triggering a UBO check.
- Annual confirmation: there is no formal annual UBO confirmation requirement at present, but periodic accuracy checks are expected, and the data must always reflect reality.
Forming now? UBO filing is included in our all-in package, the notary handles it inside the KvK registration. See how formation works →
Who can access it
This is the question most non-resident founders care about, and the honest answer changed materially in late 2022. Before then the Dutch UBO register was, in effect, publicly searchable. That ended with the 22 November 2022 CJEU ruling in joined cases C-37/20 and C-601/20, which found that unrestricted public access was a disproportionate interference with privacy rights under the EU Charter.
Since that ruling, access is limited to defined categories:
- Competent authorities, including FIU-NL (the financial-intelligence unit), the police, the Belastingdienst (tax authority), the AFM and DNB (the financial-markets and central-bank regulators).
- AML-obliged entities, such as notaries, banks, lawyers, accountants and real-estate agents, when carrying out their customer-due-diligence duties on you specifically.
- Parties demonstrating a legitimate interest, under the framework operationalised in the Wetsvoorstel beperking toegang UBO-register and the implementing measures finalised in stages through 2024 and 2025.
Who can no longer access it freely: the general public, and researchers or journalists who do not have a specific approved request. For a privacy-conscious founder this is a real improvement over the pre-November-2022 era, when anyone could look you up.
What "legitimate interest" means in practice
The legitimate-interest gateway is narrow by design. A party requesting access must demonstrate a concrete, lawful purpose tied to the aims of the anti-money-laundering regime, for example AML diligence on a specific transaction, or a journalistic investigation into a specific case of suspected money laundering or terrorist financing. Generic curiosity, competitive snooping, or harvesting data for marketing is no longer sufficient grounds, and such requests are refused. The specifics of how requests are assessed were finalised in the late-2024 and July-2025 implementing measures.
Penalties for non-compliance
Keeping the register accurate is not optional. The sanctions sit across administrative, criminal and practical layers.
- Failure to register can attract an administrative fine of up to €22,500 under the Wwft and the Handelsregisterwet.
- Material non-disclosure or false disclosure can give rise to criminal exposure, not just a fine.
- The KvK can block updates to your registration if the UBO data is stale, which gums up unrelated filings.
- Banks may refuse or freeze accounts. A bank cannot complete its own AML duties if your UBO data is missing or wrong, so a stale register can quietly stall your banking. With your fintech account this is the most common real-world bite.
Multiple UBOs and pseudo-UBOs
A BV can have more than one UBO. Two founders each holding 40%, for example, are both UBOs, and each person's data is collected and registered independently. There is no single "main" UBO; everyone over the 25% threshold goes on file.
Where no individual meets the 25% test, because ownership is genuinely diffuse, the regime does not leave the register empty. Instead the BV's directors are registered as pseudo-UBOs: they are recorded as UBOs by virtue of their senior management role rather than any ownership stake. This is common in widely-held BVs and in investment-fund structures. The pseudo-UBO route is a fallback for when a real owning individual cannot be identified, not a way to avoid naming one who can.
A foreign entity in the cap table
If your BV is owned by a foreign corporate entity, the UBO test "looks through" that entity. You cannot register the foreign company as the UBO: you must identify the ultimate natural person or persons who control it. Where that ownership chain runs through several layers or jurisdictions, you trace it to the top. Apostilled proof of beneficial ownership at the foreign entity forms part of the KYC we collect during formation, so it is worth gathering that documentation early if your structure is not a simple direct shareholding.
Layering a Dutch Holding above an Operating BV changes who the UBO traces through, but not the underlying test. Read the holding-structure guide → or see the holding service →
The privacy reality
Most non-resident founders considering the Netherlands ask about privacy first. The honest position after November 2022 is neither "fully private" nor "all public", and it is worth being precise:
- No longer publicly listed. The register is not searchable by the general public, which is a meaningful improvement.
- Still seen by many regulated parties. Your bank, your notary and your accountant all see your UBO data as part of their own due diligence. It is restricted, not secret.
- Still not leak-proof. No register is immune to breaches; restricted access lowers exposure but does not eliminate it.
- Comparatively reasonable. The Dutch register is now closer to Germany's (private, restricted access) than to the UK's, where many beneficial-ownership records remain publicly available.
If absolute privacy is your single overriding requirement, no EU jurisdiction with a functioning AML regime will deliver it. The Netherlands sits in a sensible middle: a credible, restricted-access register, paired with banking that actually onboards non-resident founders.
Updating UBO data
Because the 7-day window is tight, it is worth knowing exactly which events trigger an update. The common ones are:
- A new shareholder acquires more than 25%.
- An existing UBO's stake drops below 25%.
- A UBO changes their country of residence, legal name, or nationality.
- A pseudo-UBO (a director) changes, in a structure relying on the director fallback.
We file these updates from your dashboard at €145 per change, so a transfer of shares or a director swap does not become an administrative scramble against the clock. See the add-ons on our pricing page →