UBO registration is the entry, in the Handelsregister (Business Register) kept by the KVK, of the natural persons who ultimately own or control a BV, NV, foundation or other listed entity: in a BV or NV, anyone holding more than 25 percent. The notary files at incorporation, a director files changes within one week, and the data are not public.
This guide covers who is a UBO, what is recorded, how a founder abroad files, the deadline, access as at 4 October 2026, the extract, shielding and sanctions. The company's own registration, with which the notary registers the UBOs, is in the KVK registration guide.
What is the Dutch UBO register?
The Dutch UBO register is not a separate database. Under art. 15a lid 1 of the Handelsregisterwet 2007 (Hrw 2007, the Business Register Act), the UBOs of the entities named in art. 10a lid 2 Wwft that are registered under art. 5 or 6 Hrw 2007 are recorded in the Handelsregister, on the company's own entry under its kvk number.
Art. 10a lid 1 of the Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft, the anti-money-laundering act) defines the UBO as the natural person who ultimately owns or controls the company or other legal entity; in the KVK's words, "a legal entity can never be a UBO".
The KVK records but does not judge: "KVK does not determine who the UBOs are." The entity answers for the data, which must be correct and complete at all times (art. 19 lid 1 Hrw 2007), and the UBO must give it the information it needs (art. 10b lid 2 Wwft).
Trusts and similar arrangements have their own UBO register, in which the trustee registers within 7 days (business.gov.nl).
Who counts as a UBO of a Dutch BV or NV?
The ownership test
For a BV or NV, art. 3 lid 1 sub a 1° of the Uitvoeringsbesluit Wwft 2018 (the Wwft implementing decree) names the natural person who holds, directly or indirectly, more than 25 percent of the shares, of the voting rights or of the ownership interest in the company, bearer shares included. However long the chain of companies, the UBO is always a natural person.
Control by other means and effective control
The same provision covers control by other means, which includes the consolidation tests used for annual accounts (art. 2:406 BW). The KVK adds feitelijke zeggenschap (effective control), with the example of a voting agreement under which one shareholder votes for all. Its example of an economic interest is depositary receipts held through a STAK, the administration foundation described on the stichting netherlands page.
KVK's order of tests
The KVK's checklist for a BV, NV, SE or SCE runs the tests in a fixed order: shares, then voting rights, then economic interest, then effective control. "Select the first interest that applies to the people in your organisation. You must then register the UBOs with that interest." If none applies, all managing directors are registered. The order is the KVK's practice, not a rule printed in the decree.
Bands on the register
The register records a band, not the exact percentage. Art. 35b lid 1 of the Handelsregisterbesluit 2008 (Hrb 2008, the Business Register Decree) sets three.
The three bands in which a UBO's interest is recorded. Source: art. 35b lid 1 Hrb 2008, version of 1 January 2026.
| Band on the register | What it covers |
|---|---|
| More than 25 up to and including 50 percent | an interest above the threshold, up to half |
| More than 50 up to and including 75 percent | a majority interest, up to three quarters |
| More than 75 up to and including 100 percent | an interest above three quarters, sole ownership included |
- Is the holder a legal entity?Look through every company to the natural persons: a legal entity is never a UBOApply the four tests in order; the first that applies decides (KVK checklist)
- More than 25 percent of the shares?Register those natural persons as UBOsTest the voting rights
- More than 25 percent of the voting rights?Register those natural persons as UBOsTest the economic interest
- An economic interest of more than 25 percent, such as depositary receipts through a STAK?Register those natural persons as UBOsTest effective control
- Effective control, such as a voting agreement?Register those natural persons as UBOsAll means exhausted, no grounds for suspicion: every director within art. 2:9 BW is registered as pseudo-UBO (art. 3 lid 6 Uitvoeringsbesluit Wwft 2018)
What if nobody holds more than 25 percent? The pseudo-UBO
When no natural person passes any test, the decree does not leave the entry empty, but it sets a condition first. Only after all possible means are exhausted, and provided there are no grounds for suspicion, or where there is doubt, are the senior managing officials (hoger leidinggevend personeel) registered (art. 3 lid 1 sub a 2° Uitvoeringsbesluit Wwft 2018).
Art. 3 lid 6 says who they are: every director (bestuurder) within the meaning of art. 2:9 BW, and nobody else. These are the pseudo-UBOs.
This is a fallback reached under that condition, not a second category beside the shareholders: where shares are spread so that nobody holds more than 25 percent and nobody controls by other means, the board goes into the register. Who a director of a Dutch BV is, and what liability attaches to the role, is explained in the guide on a local director for a Dutch BV.
Which organisations must register UBOs, and which are exempt?
Who registers UBOs and who is exempt. Source: business.gov.nl, UBO register, checked on 29 September 2026.
| Must register UBOs | Exempt |
|---|---|
| Unlisted BVs and NVs | Eenmanszaak (sole proprietorship) |
| Foundations (stichtingen) | Listed BVs and NVs |
| Associations with full legal capacity, and those with limited capacity that run a business | 100 percent subsidiaries of listed companies |
| Mutual insurers and cooperatives | Owners' associations |
| Partnerships: maatschap, VOF, CV | Entities in formation |
| Shipping companies and churches | Associations without a business |
| SE and SCE | Public-law entities |
| EEIGs seated in the Netherlands | Historical bodies |
Residence and nationality make no difference. In business.gov.nl's words, "It makes no difference if this person lives in the Netherlands or abroad, nor does their nationality." A founder living abroad who owns a Dutch BV is registered in the same way as a resident.
A foreign company that operates here only through a branch is the exception: "Foreign companies that only have branch offices in the Netherlands do not have to register their ultimate beneficial owners in the Netherlands." Their beneficial owners are recorded in the home country's register instead.
What is recorded, and which documents does the KVK need?
What the register records
Art. 15a lid 2 Hrw 2007 lists what is recorded about each UBO, including the BSN (Dutch citizen service number) and a foreign tax identification number (TIN) where issued. Table 3 pairs each item with the KVK access levels that see it.
What is recorded about a UBO and which KVK access level sees it. Sources: art. 15a lid 2 Hrw 2007; KVK access levels (KVK practice, page edited 20 August 2026).
| Item recorded | Legal basis | UBOB1 | UBOB2 | UBOB3 |
|---|---|---|---|---|
| Nature and extent of the interest (the band) | art. 15a lid 2 Hrw 2007 | yes, if not shielded | yes | yes |
| Name | art. 15a lid 2 Hrw 2007 | yes, if not shielded | yes | yes |
| Month and year of birth | art. 15a lid 2 Hrw 2007 | yes, if not shielded | yes | yes |
| State of residence and nationality | art. 15a lid 2 Hrw 2007 | yes, if not shielded | yes | yes |
| Day, place and country of birth; home address | art. 15a lid 2 Hrw 2007 | no | no | yes |
| BSN or foreign TIN | art. 15a lid 2 Hrw 2007 | no | no | yes |
Documents deposited
Art. 15a lid 3 adds copies of the identity documents used for verification and of the documents proving the interest. Art. 35b lid 2 Hrb 2008 accepts as interest documents the shareholders' register, the articles, the certificate holders' register, the deed of incorporation, another notarial deed, the members' register, a partnership contract, the Handelsregister entry, an organisation chart or other relevant documents.
One shortcut: if the UBO directly holds 100 percent, is a natural person and is registered as sole shareholder, "Then you do not need to add documents showing the interest of the UBO."
If a UBO lives abroad
- Personal data the KVK asks for: first names and surname; date, country and place of birth; TIN and issuing country, if available; nationality; residential address.
- ID copy, for new UBOs only: the BSN visible, front and back, in full colour and at actual size, with the nationality not covered; the photo may be blurred.
- File formats online: PDF, JPG, PNG, GIF or BMP, at most 25 MB per document.
- By post: A4 paper.
No apostille or sworn-translation requirement appears on the KVK UBO pages read for this guide; whether the KVK asks for either on a foreign shareholder document is not published there.
Who files the UBO report, and how do you file from abroad?
At incorporation: the notary
For a new BV or NV the founder does not file the UBOs: "the civil-law notary arranges the registration in the KVK Business Register and registers its UBOs", through the notaries' own channel, the Notaris Applicatie UBO (KNB). The formation itself is described on the Dutch BV page.
Determine the UBOs
with the notary, using the KVK's ordered tests. No official time is published for this step.
Collect the documents
per UBO, the ID copy, the personal data and the interest documents (none under the sole-shareholder shortcut). No official time is published for this step.
Deed and filing
the notary registers the company and its UBOs within one week of the deed (art. 20 lid 1 Hrw 2007).
Confirmation
the KVK sends each UBO a confirmation letter; UBO processing took about 4 working days in the KVK's September 2026 figures.
Keep the letter
where no UBO extract can be ordered, it is the proof a bank can be given.
After incorporation: a director
Afterwards each director is obliged to file (art. 18 lid 1 Hrw 2007), and the authorised signatories sign the UBO report, which registers, changes or deregisters UBOs (inschrijven, wijzigen, uitschrijven). Changes and deregistrations can also be made in My KVK, the KVK's online account; a first registration cannot: "You cannot register UBOs in My KVK."
Without a BSN or DigiD
Online filing needs DigiD, the Dutch government login; by post, the signatory sends a copy of a valid identity document. A non-Dutch non-resident reaches DigiD through the RNI (Non-Residents Records Database): "After registration with the RNI, you will immediately receive a citizen service number (BSN)." The DigiD application follows.
At incorporation none of this is needed, because the notary files. The KVK pages read name DigiD for online filing and the post route otherwise, not eHerkenning or a European eID.
Statutory or official timePractice indication
- Deed of incorporationThe notaryStarts the one-week clock
- Company and UBOs filedThe notaryWithin one week (art. 20 lid 1 Hrw 2007)
- KVK processingThe KVKAbout 4 working days (KVK figures, September 2026)
- Confirmation letterThe KVK, to each UBONo official time
- Later UBO changesA director or authorised signatoryWithin one week (art. 20 lid 2 Hrw 2007) No deferral
- A director abroad files a changeRNI registration, then BSN, then DigiD and file online; or by post with an ID copyNo official time
DutchRegist: eHerkenning for a Foreign-Owned Company A separate business login, covered in its own guide; the KVK pages read do not name it for the UBO report.
No Dutch company yet? We prepare the file the notary works from for founders abroad, the UBO documents included.
How quickly must a UBO change be filed?
A UBO change, step by step. Sources: art. 20 lid 2 Hrw 2007; KVK UBO report page, checked on 4 October 2026; KVK processing times, September 2026.
| Step | Who | Timing |
|---|---|---|
| The event becomes official (for a share transfer, the notarial deed of transfer) | the notary and the parties | starts the clock |
| File the UBO report, or use My KVK for a change or a deregistration | an authorised signatory; in a BV every director is obliged to file | |
| Where a UBO is deregistered, register who replaces them | the signatory | in the same filing |
| Deadline | no later than one week after the event (art. 20 lid 2 Hrw 2007); the KVK says within 7 days | |
| Extension | none: the KVK has no legal power to grant a deferral | |
| Processing | the KVK | about 4 working days (September 2026) |
The statute says within one week (art. 20 lid 2 Hrw 2007); the KVK's UBO report page puts it as 7 days: "You must file a UBO report to notify us of any changes in the UBO details within 7 days of the changes becoming official." On extensions it is blunt: "No, KVK has no legal power to grant a deferral. Not even for exceptional cases."
A foreign UBO's change of address goes on KVK form 18, not the UBO report. Where the directors are pseudo-UBOs, a new director is also a UBO change; the corporate side of changing a director or the seat of a Dutch BV has its own page.
For a buyer of an existing BV, the UBO change after the notarial deed of transfer is the company's own filing within the same week; the transfer from the buyer's side is covered on the ready-made companies page.
Who can see the UBO register in 2026?
As at 4 October 2026, in the KVK's words: "Information from the UBO Register is not public."
Why public access ended
On 22 November 2022 the Court of Justice of the EU (Grand Chamber, joined cases C-37/20 and C-601/20) held that public access to this data "constitutes a serious interference with the fundamental rights enshrined in Articles 7 and 8 of the Charter", and declared invalid the directive's rule giving any member of the public access in all cases. General public access ended with that judgment.
Who has access now
Access now rests on the Act of 14 July 2025 restricting access to the UBO registers (Stb. 2025, 189), in force since 16 July 2025 (decree of 21 May 2026, Stb. 2026, 125); two parts, art. I part B under 2 and art. II part C, have no published start date. Under art. 22a Hrw 2007:
- Wwft and Sanctions Act 1977 institutions, for customer due diligence under the Wwft or the Wtt 2018, see the data of art. 15a lid 2 sub c and e only (lid 1).
- The entity sees its own data and documents (lid 6).
- The UBO may ask how many times their data were provided (art. 22 lid 6).
The KVK lists the sectors that can now apply: civil-law notaries, banks, trust companies, licensed life insurers, and AFM-licensed investment firms and credit providers. Since April 2026 a certified PDF extract is available through an API or the KVK website; structured JSON (API-UBO 2.0) is announced for 2027.
KVK's three access levels
These levels are KVK practice; their statutory basis is not established in the sources read.
The KVK's access levels to UBO data (KVK practice, page edited 20 August 2026).
| Access level | What it shows |
|---|---|
| UBOB1 | the interest, name, month and year of birth, country of residence and nationality, only if the UBO is not shielded |
| UBOB2 | the interest, name, month and year of birth, country of residence and nationality |
| UBOB3 | the UBOB2 data plus date, place and country of birth, residential address, and the BSN or TIN |
The draft legitimate-interest decree
Art. 22a lid 2 Hrw 2007 lets a decree add categories of persons with a demonstrable legitimate interest; the UBO is told of a granted request and its purpose (lid 3), and the draft must lie before both Chambers for four weeks (lid 7).
That decree is still a draft, consulted on from 28 November 2025 to 9 January 2026, with commencement by Royal Decree. The draft proposes categories such as journalists and persons about to transact with the entity, and a KVK decision within 12 working days. None of it is law as at 4 October 2026.
Can you search the UBO register for a company's owners?
No. There is no public name search of the Dutch UBO register: access is limited to the institutions, entities and persons in art. 22a Hrw 2007, and the KVK states that the register is not public. Who can look, and on what basis, is set out above.
What anyone can check is the company's own public registration in the Dutch Business Register; the guide on that register explains what it holds and which extracts exist.
How do banks use the UBO register?
For a Dutch bank the register is a starting point, not an afterthought. Before the business relationship starts, the institution establishes whether the client's UBOs are registered (art. 4 lid 2 Wwft). If it finds that the register differs from what it learns itself, it must report the discrepancy: "Een instelling doet melding aan de Kamer van Koophandel van iedere discrepantie die zij aantreft" (art. 10c lid 1 Wwft), every discrepancy it finds goes to the KVK. Shielding does not hide the data from banks and other financial undertakings (art. 51b lid 1 Hrb 2008).
The order follows mechanically: the UBO filing comes before the account. The registration is therefore in place before opening a corporate bank account in the Netherlands begins. Where the UBO extract cannot be ordered, the KVK confirmation letter serves as proof, as the next section explains.
How do you get a UBO extract, and what does it cost?
The KVK UBO register extract in 2026. Sources: art. 1 sub g Financiële regeling handelsregister 2019; KVK extract page, checked on 29 September 2026.
| Item | The UBO extract (KVK uittreksel UBO-register) |
|---|---|
| Tariff | EUR 3.10 (2026), art. 1 sub g Financiële regeling handelsregister 2019 |
| Form | digital only, electronically sealed |
| Language | Dutch only |
| Availability | downloadable for 24 hours via My KVK |
| Who may order | an authorised signatory, or an organisation authorised to view UBO data; not a UBO who is not a signatory |
| Login on the extract page | DigiD or a European eID |
The price is a statutory tariff (art. 1 sub g of the Financiële regeling handelsregister 2019), and the KVK confirms: "The UBO extract costs €3.10 and is only available in Dutch." To order (bestellen) and download (downloaden) it, the signatory logs in to My KVK.
Two limits catch foreign founders: "Are you a UBO, but not authorised to sign? Then you cannot order a UBO extract." And: "It is only possible to order a UBO extract if you are registered as a natural person with this business." A director who sits on the board through another legal entity, as in a Dutch holding structure, may therefore be unable to order it; the KVK confirmation letter then counts as proof.
Can UBO data be shielded, and how long are records kept?
The four grounds on which UBO data can be shielded. Source: art. 51b leden 2 to 4 Hrb 2008, version of 1 January 2026.
| Ground (art. 51b lid 2 Hrb 2008) | How long the shielding lasts |
|---|---|
| Police protection under art. 42 lid 1 sub c Politiewet 2012 | five years, renewable by five years each time |
| The UBO is under 18 | until the UBO turns 18 |
| The UBO is under curatele (guardianship) or bewind (administration) ordered by the cantonal judge | until the incapacity ends |
| The UBO is legally incapable abroad | until the incapacity ends |
Shielding is narrow, and it is not a privacy setting. The four grounds are personal safety, age and legal incapacity, and there is no other. Shielding also never blinds the state or the banks: shielded data stay visible to the FIU (the Dutch Financial Intelligence Unit), the competent authorities, banks and other financial undertakings (art. 51b lid 1 Hrb 2008).
The data also outlive the company. UBO data and the deposited copies can be inspected for up to ten years after the entity is struck off the Handelsregister (art. 51c Hrb 2008). Dissolving a company does not erase its UBO history.
What are the penalties for late or wrong UBO registration?
Sanctions for a missing, late or wrong UBO filing, 2026. Sources: arts. 47 to 47c Hrw 2007; art. 23 lid 4 Sr; WED.
| Measure | Legal basis | Ceiling or penalty |
|---|---|---|
| The offence: acting against, or not meeting, a filing duty | art. 47 Hrw 2007 | the basis for every measure below |
| Order subject to a penalty (last onder dwangsom) by the Minister of Finance | art. 47a Hrw 2007 | set in the order |
| Administrative fine (bestuurlijke boete) | art. 47b lid 2 Hrw 2007 with art. 23 lid 4 Sr | at most the fourth-category amount: EUR 27,500 from 1 January 2026 |
| Information power: cooperation within a reasonable term the Minister sets | art. 47c lid 1 Hrw 2007 | |
| Criminal route: an economic offence (art. 1 under 4° WED), an overtreding (art. 2 lid 1 WED) | art. 6 lid 1 under 5° WED | detention up to six months, community service or a fourth-category fine |
Art. 47 Hrw 2007 makes any breach of a filing duty an offence. The fine ceiling is the fourth-category amount of art. 23 lid 4 of the Wetboek van Strafrecht (the Criminal Code), EUR 27,500 from 1 January 2026; the consolidated text still prints EUR 16,750, with an editorial note giving the 2026 amount.
The Wet op de economische delicten (WED, the Economic Offences Act) adds the criminal route. These are ceilings: no enforcement policy or enforcement figures were read for this guide, so it states no typical fine; and with no deferral available, there is no extension to rely on.
From our practice
Joost van Leeuwen, Company formation and company law lead, eleven years on Dutch company files, assembles the UBO documents for the notary's file. Founders abroad first ask whether they need DigiD: at incorporation they do not, because the notary registers the UBOs, and for later changes the post route with an ID copy remains.
Reviewed by Ilse Brouwer, Tax, VAT and licensing lead, on 4 October 2026.
Sources
- Handelsregisterwet 2007, arts. 15a, 18 to 20, 22, 22a and 47 to 47c, consolidated version valid from 16 July 2025, wetten.overheid.nl, checked on 29 September 2026
- Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft), arts. 4, 10a, 10b and 10c, wetten.overheid.nl, checked on 29 September 2026
- Uitvoeringsbesluit Wwft 2018, art. 3, version of 30 April 2026, wetten.overheid.nl, checked on 4 October 2026
- Handelsregisterbesluit 2008, arts. 35b, 51b and 51c, version of 1 January 2026, wetten.overheid.nl, checked on 29 September 2026
- Financiële regeling handelsregister 2019, art. 1 sub g, wetten.overheid.nl, checked on 29 September 2026
- Wetboek van Strafrecht, art. 23 lid 4, wetten.overheid.nl, checked on 29 September 2026
- Act of 14 July 2025 restricting access to the UBO registers, Stb. 2025, 189, zoek.officielebekendmakingen.nl, checked on 29 September 2026
- Court of Justice of the EU, Grand Chamber, 22 November 2022, joined cases C-37/20 and C-601/20, eur-lex.europa.eu, checked on 29 September 2026
- KVK, Who are the UBOs in your organisation, checked on 4 October 2026
- KVK, About My KVK, checked on 3 October 2026
- KVK, UBO report, checked on 4 October 2026
- KVK, KVK UBO register extract, checked on 29 September 2026
- Wet op de economische delicten (WED), arts. 1, 2 and 6, checked on 29 September 2026: https://wetten.overheid.nl/BWBR0002063
- Decree of 21 May 2026, Stb. 2026, 125, checked on 29 September 2026: https://zoek.officielebekendmakingen.nl/stb-2026-125.html
- KVK, What information and documents from the UBOs do you need (checked on 4 October 2026): https://www.kvk.nl/en/ubo/what-information-and-documents-from-the-ubos-do-you-need---g1/
- KVK, Who can report UBOs (checked on 4 October 2026): https://www.kvk.nl/en/ubo/who-can-report-ubos-g1/
- KVK, Registering a Dutch BV or NV (checked on 29 September 2026): https://www.kvk.nl/en/registration/registering-a-dutch-bv-or-nv/
- KVK, About the UBO register (checked on 29 September 2026): https://www.kvk.nl/en/ubo/about-the-ubo-register/
- KVK, Current processing times (September 2026 figures, checked on 29 September 2026): https://www.kvk.nl/en/help-and-contact/current-processing-times/
- business.gov.nl, UBO register: ultimate beneficial owner (checked on 29 September 2026): https://business.gov.nl/regulations/ubo-register-ultimate-beneficial-owner/
- KVK, Who has access to UBO data (page edited 20 August 2026, checked on 29 September 2026): https://www.kvk.nl/en/ubo/who-has-access-to-ubo-data/
- KVK, UBO access expanded (page edited 20 August 2026, checked on 29 September 2026): https://www.kvk.nl/en/ubo/ubo-access-expanded/
- KNB (Royal Dutch Association of Civil-law Notaries), UBO register (checked on 29 September 2026): https://www.knb.nl/kennisbank/fraudepreventie-wwft/ubo-register/
- Draft Wijzigingsbesluit toegang UBO-registers voor natuurlijke personen en rechtspersonen met een legitiem belang, with explanatory note: a draft, consulted 28 November 2025 to 9 January 2026, not in force
Related service
the Dutch BV page For a founder abroad who has no Dutch company yet: how a BV is formed through a notary, who registers its UBOs with the first registration, and what the founder supplies.