The UBO register exists in every EU country because the underlying rules come from the same European directive on money laundering. Yet the implementation is not the same in every country. Who gets access to the register, which percentages apply to the definition of an ultimate beneficial owner, which exceptions exist and how you must submit information: each country regulates this in its own way. For an entrepreneur who operates only in the Netherlands, this makes little difference. Once you have an establishment in another EU country, or a foreign customer asks you for a UBO extract from another country, you will run into these differences.
UBO stands for ultimate beneficial owner, the natural person who ultimately has control over a business or owns it, even if this is through multiple intermediate companies. Every EU country keeps a register of these persons per business registered in its territory. This is the common basis. What happens next with that register varies.
What remains the same in every country
The idea behind the register is the same everywhere: supervisors, banks and sometimes also business partners must be able to check who really stands behind a business, so that it becomes harder to conceal ownership. The obligation to register UBOs applies to legal entities in all Member States, and the definition of a UBO is established at European level in principle. The link with other checks, such as the KYB check that banks and insurers carry out, also occurs in every country, although the exact procedure may differ. More information about what KYB exactly means can be found in the knowledge base by topic.
What does vary by country
The biggest difference is in access to the register. Some countries give broad public access, other countries restrict access to bodies with a legitimate interest, also following rulings on privacy at European level. This means that an extract you can easily download yourself in one country is only available in another country through a formal request.
The threshold values and exceptions also vary. The directive provides a framework, but countries are free to make their own choices within it on, for example, the exact percentages or which legal forms are exempt. In addition, the frequency with which you must report changes varies, and the way a register deals with newly established businesses.
Finally, the form of the certificate varies. One country provides a digital extract with a unique code, another country provides a PDF with a stamp or a declaration that must be requested separately. If a foreign customer asks for proof of UBO in its portal, it could therefore be a different type of document than what you are used to in the Netherlands.
Why this may be important for you
If you only supply in the Netherlands and your customers do too, this is mainly background information. Once you have a subsidiary in another EU country, or a customer in another country asks you for a UBO declaration, it is good to know that you cannot automatically send the same document that is sufficient in the Netherlands. The register where you must be, the form of the proof and sometimes also the waiting time for a request are then different from what you are used to.
This is particularly relevant for businesses with activities in multiple countries, or for suppliers working through a foreign holding. For most SMEs supplying from the Netherlands, the Dutch Business Register remains the point of reference, even if the customer is abroad. If you are unsure whether your situation falls under another country, then the Chamber of Commerce or a lawyer is the right place to check, not a software supplier.
Because each country manages its own register and its own single point of contact, there is no central European overview where you can look everything up in one go. For each topic, we do set out where to find the official sources and what is deliberately still undetermined in them, so you know where to look instead of having to figure it out yourself. You can read more about how that information is created on the page about our working method.
If you would first like to see whether this topic is relevant for your company, you can check that in a few questions via the free check where you are now. Even if you mainly deal with questionnaires from domestic customers, it is worthwhile to know what changes as soon as a customer or location crosses the border. If you have a specific question about a register in another country, first check the frequently asked questions to see if that topic is already explained there.
This explanation is descriptive in nature and not legal advice on your own situation. For an assessment of what applies in your case, the competent supervisory authority in the country concerned or a lawyer is the appropriate contact.