The Belgian Minister of Finance, Alexander De Croo, announced that the deadline for the obligatory registration of Belgian entities in the Ultimate Beneficial Owner (UBO) register will be postponed until September 30, 2019 (before it was March 31, 2019). This delay is due to uncertainties regarding the scope of the obligation and IT issues for the online registration. Currently, the obligation exists for all companies, partnerships, non-profit organisations, trusts, fiduciaries and foundations.

The obligation to register Belgian entities in the UBO register stems from the anti-money laundering act, which transposes the fourth anti-money laundering directive (EU 2015/849) into Belgian law. Knowing who effectively is behind a legal entity is important to step up the fight against money laundering and the financing of terrorism.

The anti-money laundering act obliges certain Belgian entities to register the identity of the natural persons/shareholders who directly or indirectly hold more than 25 percent of the interests in aforementioned entity (voting rights or ownership). If a legal entity has control, the underlying beneficiaries of that entity must be notified. In a chain of ownership, the reporting agent will therefore have to examine all levels of the ownership structure.

Of the estimated 800,000 to 1 million legal entities that have to register in the UBO register, only 25,000 have so far done so. This is due to a series of uncertainties for Belgian entities. For example, there are still many questions about the exact scope of the UBO registration and many non-profit organizations are currently unaware of their obligations. Furthermore, there are a series of IT problems that have complicated the online registration.

Finance Minister Alexander De Croo now wants the FPS Finance to put an end to any remaining ambiguities for Belgian legal entities by publishing a new FAQ on UBO registration.

In light of the foregoing, the Minister has decided to postpone the deadline for registration until September 30, 2019. This date also has the advantage of coinciding with the deadline for filing corporate income tax returns.

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