The UBO (Ultimate Beneficial Owner) declaration is a legal requirement for every company, non-profit association, foundation and trust registered in Belgium. This register, run by FPS Finance (Treasury), is designed to identify the individuals who actually own or control a legal entity. In this complete tutorial, we guide you step by step through filing your UBO declaration on the MyMinfin platform.

What is the UBO register?

The UBO register (Ultimate Beneficial Owner, or "bénéficiaire effectif ultime" in French) was created under the law of 18 September 2017, transposing the EU's 4th anti-money laundering directive (Directive 2015/849). It centralises information about the individuals who ultimately own or control Belgian legal entities.

Objectives of the UBO register

The register serves several purposes:

  • Combating money laundering: identifying the real owners behind complex legal structures
  • Combating terrorist financing: tracing financial flows back to individuals
  • Financial transparency: meeting European and international requirements (FATF)
  • International cooperation: making it easier for EU member states to exchange information

Who needs to file a UBO declaration?

Every legal entity registered with the Crossroads Bank for Enterprises (BCE) must file a UBO declaration. This includes:

Entity type UBO obligation Examples
Trading companies Yes SRL, SA, SC, SNC, SComm
ASBL Yes Non-profit associations
AISBL Yes International non-profit associations
Foundations Yes Private and public-benefit foundations
Trusts and fiduciary structures Yes Similar legal constructions
Self-employed individuals No No separate legal structure

Who counts as a beneficial owner?

The definition of a beneficial owner varies depending on the type of legal entity:

For companies

The following are considered beneficial owners:

  1. Individuals who directly or indirectly hold more than 25% of the shares or voting rights of the company. For example, if you hold 30% of the shares in an SRL, you are a beneficial owner.

  2. Individuals who control the company through other means: shareholder agreements, veto rights, the right to appoint or remove the majority of directors, and so on.

  3. In the absence of the above categories: individuals who hold a senior management position (manager, managing director, CEO).

For non-profits and foundations

The following are considered beneficial owners:

  • Members of the board of directors
  • Individuals authorised to represent the association
  • Individuals responsible for day-to-day management
  • Founders (for foundations)
  • Individuals or categories of individuals in whose main interest the entity was set up
  • Any other individual who exercises ultimate control through other means

The concept of indirect control

Indirect control deserves particular attention. This is where an individual controls a company through one or more intermediate entities. For example:

  • Mr Dupont holds 60% of Company A
  • Company A holds 50% of Company B
  • Mr Dupont is therefore an indirect beneficial owner of Company B (60% x 50% = 30%, above the 25% threshold)

Prerequisites before you start

Before starting your UBO declaration, make sure you have the following ready:

1. An electronic authentication method

To access MyMinfin and the UBO register, you need one of the following authentication methods:

  • Electronic identity card (eID) plus a card reader: the most common method in Belgium. You will need your eID PIN code.
  • The itsme app: Belgium's mobile digital identification app, available on iOS and Android. Free to download.
  • A token security code: provided by your bank (if it participates in the CSAM system).

2. Information required about the beneficial owner

For each beneficial owner you declare, you need:

  • Full first name and surname
  • Date of birth
  • Nationality/nationalities
  • Full address (street, number, postcode, municipality, country)
  • National register number (for Belgian residents) or a foreign tax identification number
  • The date the person became a beneficial owner
  • Percentage of economic interest (percentage of shares or voting rights)
  • Category of beneficial owner (direct control, indirect control, senior manager, etc.)

3. Supporting documents

The legislation requires supporting documents to be attached to the declaration. These documents must prove that the information is adequate, accurate and current:

  • Extracts from the shareholder register
  • The company's articles of association (coordinated version)
  • The deed of incorporation
  • The shareholder agreement (if applicable)
  • An organisational chart of the group structure (in the case of indirect control)
  • Any other relevant document (AGM minutes, contracts, etc.)

Documents must be in PDF format and no larger than 11 MB per file.

Step-by-step tutorial: UBO declaration on MyMinfin

Step 1: Access the platform

  1. Open your browser and go to https://eservices.minfin.fgov.be/ubo/
  2. You will land on the UBO register homepage. Click "Log in" (top right) or "Access the UBO application".
  3. You will be redirected to the CSAM authentication page (the federal authentication platform).
  4. Choose your login method:
    • eID: insert your identity card into the reader, click "Log in with eID" and enter your PIN code
    • itsme: click "Log in with itsme", open the itsme app on your smartphone and confirm the login
  5. Once authenticated, you will reach the UBO register dashboard.

Tip: If you are using your eID, check that the eID middleware is installed on your computer. You can download it free of charge from eid.belgium.be.

Step 2: Select your entity

  1. On the dashboard, you will see a list of entities for which you are authorised to file a declaration (as legal representative or proxy holder).
  2. If your entity does not appear, click "Add an entity" and enter the enterprise number (CBE number, in the format 0XXX.XXX.XXX).
  3. Click the name of the relevant entity to access its UBO record.

Important: Only the following people can file the UBO declaration for an entity:

  • The entity's legal representative (manager, director)
  • A proxy holder appointed via a UBO mandate registered in the system

Step 3: Add a beneficial owner

  1. On your entity's record, click "Add a beneficial owner".
  2. A form will open. Fill in the following fields:

Identifying the beneficial owner:

  • Select whether the person is a Belgian resident (with a national register number) or a non-resident
  • For a Belgian resident: enter the national register number. The system automatically retrieves the name, first name and date of birth from the National Register
  • For a non-resident: manually enter the first name, surname, date of birth, nationality/nationalities and full address

  1. Select the beneficial owner's category from the drop-down menu:

    • Direct ownership (percentage of shares/voting rights > 25%)
    • Indirect ownership (via one or more intermediate entities)
    • Control through other means
    • Senior manager (residual category)

  2. State the percentage of shares and/or voting rights held by the beneficial owner. If control is indirect, you will also need to state the intermediate entities and the percentages at each level.

  3. Start date: state the date from which the person became a beneficial owner (date the company was set up, date the shares were acquired, etc.).

Step 4: Attach the supporting documents

  1. At the bottom of the form, you will find the "Supporting documents" section.
  2. Click "Add a document".
  3. Select the document type from the drop-down menu:
    • Extract from the shareholder register
    • Coordinated articles of association
    • Deed of incorporation
    • Organisational chart
    • Other document
  4. Click "Browse" and select the PDF file on your computer.
  5. The file is uploaded. You can add as many documents as needed.

Practical tip: Prepare a clear organisational chart of your shareholding structure in advance. This will make the administration's verification much easier and avoid requests for further information.

Step 5: Validate and confirm the declaration

  1. Carefully check all the information you have entered.
  2. Tick the confirmation box stating that the information provided is adequate, accurate and current.
  3. Click "Confirm" to submit the declaration.
  4. A confirmation message appears on screen. You will also receive a confirmation email if an email address is linked to your account.

Important: Once confirmed, the declaration is immediately recorded in the UBO register. You can view and amend it at any time.

Step 6: Annual confirmation

Belgian legislation requires an annual confirmation of the UBO declaration. Even if nothing has changed, you must confirm each year that the information is still correct.

  1. Log in to the UBO register as described in Step 1.
  2. Select your entity.
  3. Check the existing information.
  4. If nothing has changed, click "Confirm information".
  5. If changes are needed, make them before confirming.

The annual confirmation must be made no later than one year after the last declaration or confirmation.

Deadlines and penalties

Deadlines to meet

Event Deadline
First UBO declaration Within one month of becoming aware of, or being required to know, the information about the beneficial owner
Change of information Within one month of the change (new shareholder, new manager, etc.)
Annual confirmation Every year, within one year of the last confirmation

Penalties for non-compliance

Failure to comply with UBO obligations is punished with administrative fines:

  • A fine of EUR 250 to 50,000 for the directors or managers of the entity in default
  • A fine of EUR 250 to 50,000 for the entity itself
  • Penalties are cumulative: the fine can be imposed on both the individual responsible and the legal entity

In practice, FPS Finance first sends a reminder by post before imposing a fine. Even so, it is strongly recommended not to wait for that reminder and to become compliant as soon as possible.

Practical cases and examples

Example 1: an SRL with two partners

Marie and Pierre set up a private limited company (SRL) in Brussels. Marie holds 60% of the shares and Pierre 40%. Both are beneficial owners, since each holds more than 25% of the shares.

Declaration to file:

  • Marie: direct ownership, 60% of the shares
  • Pierre: direct ownership, 40% of the shares

Example 2: an SA with dispersed shareholding

A Brussels-based SA (public limited company) has 10 shareholders, each holding 10% of the shares. No shareholder exceeds the 25% threshold. The CEO and the CFO, as senior managers, must be declared as beneficial owners (residual category).

Example 3: a structure with a holding company

Jean holds 100% of a Luxembourg holding company, which itself holds 80% of a Belgian SRL. Jean is an indirect beneficial owner of the Belgian SRL (100% x 80% = 80%, above the 25% threshold). The declaration must name the holding company as an intermediate entity.

Example 4: an ASBL

A Brussels-based ASBL has a five-member board of directors. All five members must be declared as beneficial owners, under the category "members of the board of directors".

Frequently asked questions (FAQ)

Can I authorise my accountant to file the UBO declaration?

Yes, you can appoint your accountant or chartered accountant to file the UBO declaration on your behalf. To do this, an electronic mandate must be registered via the platform. Your accountant needs access to the UBO register, and the mandate must be active before they can act.

I am the sole manager and sole shareholder of an SRL. Do I still need to file?

Yes, absolutely. You must declare yourself as a beneficial owner with 100% of the shares. Being the sole shareholder does not exempt you from the declaration requirement.

Is the information in the UBO register public?

Following a ruling by the Court of Justice of the European Union (CJEU) of 22 November 2022, public access to the UBO register has been restricted. In Belgium, access is now limited to:

  • The relevant authorities (police, public prosecutor's office, CTIF, NBB, FSMA, etc.)
  • Entities subject to anti-money laundering law (banks, accountants, notaries, lawyers, etc.)
  • People who can demonstrate a legitimate interest (under strict conditions)

What if I don't know all the beneficial owners?

The entity is required to take all reasonable steps to identify its beneficial owners. If, despite these efforts, no beneficial owner can be identified under the main categories, the senior managers must be declared instead (residual category).

Is the UBO declaration free?

Yes, registering and filing your UBO declaration on MyMinfin is entirely free. There is no access fee or filing fee.

Practical tips for an error-free declaration

  1. Prepare all your documents in advance: gather the articles of association, the shareholder register and the organisational charts before starting the online procedure.

  2. Check the percentages: make sure the percentages you declare match the actual shareholding exactly. Any inconsistency can be picked up by the administration.

  3. Don't forget indirect holdings: structures with a holding company or intermediate companies require careful calculation of the holdings at each level.

  4. Set an annual reminder: the annual confirmation is often forgotten. Put a reminder in your diary to avoid risking a fine.

  5. Update immediately when something changes: any change in shareholding or governance must be declared within one month. Don't delay.

  6. Keep a copy of the confirmation: download or print the declaration confirmation for your records. It can serve as evidence in the event of an audit.

  7. Consult your accountant or lawyer if in doubt: complex structures (multiple holding companies, trusts, shareholder agreements) often require professional advice to correctly determine the beneficial owners.

Useful resources

Conclusion

The UBO declaration is an unavoidable obligation for every Belgian legal entity. Although the procedure may seem complex at first, it turns out to be fairly simple once you have gathered the information and documents. FPS Finance's online platform is intuitive and lets you complete the declaration in just a few minutes.

The key point is not to neglect this obligation: fines can be significant, and UBO compliance is increasingly checked by banks, notaries and other financial institutions when opening accounts or handling property transactions. It is best to get your UBO declaration in order as soon as you set up your company, and to keep it up to date throughout the life of the business.

This article was written by the Espero-Soft team for the blog dedicated to entrepreneurs in Belgium. For personalised advice, do not hesitate to consult a professional (chartered accountant or lawyer).