KYB abroad: is the check the same everywhere?
Not quite. KYB stands for Know Your Business: the check that banks and insurers carry out before doing business with an undertaking. The basis comes from European rules against money laundering and terrorist financing, but those rules are laid down in a directive. A directive sets an objective and a minimum level, and each EU country implements it in its own way in national legislation. As a result, a KYB questionnaire in Germany or France looks like the Dutch one, but differs in some respects.
The biggest differences lie in three things: which register for ultimate beneficial owners (UBO) is consulted, which documents count as valid proof, and how strictly a bank or insurer wants to establish the identity of directors and shareholders. For an undertaking that supplies foreign customers, this mainly means that the same questionnaire is sometimes filled in with different attachments than you are used to in the Netherlands.
Why a directive differs by country
A European directive is not a regulation. A regulation applies directly and in the same way in all Member States; a directive must first be transposed into national legislation, and Member States have room for their own choices in doing so. Thus the threshold percentage above which someone qualifies as a UBO, the way a UBO register is maintained, and the retention period for documents can vary slightly from country to country. That is not a flaw in the system; it is how a directive is intended to work.
For your KYB file, this means that a document that suffices in the Netherlands sometimes requires an additional document in another country, for example a more recent extract or an additional declaration from the director. check by topic what is exactly being asked provides an overview of what countries typically ask for, so you do not have to go through all national legislation yourself.
UBO registers are national, not European
Each EU country maintains its own UBO register; there is no central European register that a foreign bank can easily consult. A Dutch undertaking is thus registered in the Dutch register, and a German customer who checks your details cannot always access that register directly or must follow a different process to verify the information. This is one of the reasons why foreign customers often ask for their own extract or declaration, even if you have already had that information registered in the Netherlands.
In addition, the accessibility of UBO registers differs by country: some countries grant broad access, others restrict it to parties with a demonstrable interest. This affects not only how quickly a check proceeds, but also what a foreign customer can look up himself and what he must ask you for.
Documents, translation and legalisation
A second difference lies in the form of documents. A Dutch extract from the Commercial Register is accepted without problem in most EU countries, but with customers outside the EU, a translation or legalisation may be required before a document counts as valid proof. Legalisation means that a competent authority confirms that a document is genuine, often with a stamp or declaration specifically intended for the receiving country. This does not apply to every foreign customer, but it is something you can take into account if you are supplying a party outside the EU for the first time.
Also, the validity period of documents differs. An extract that counts as current in the Netherlands for one year may be regarded as expired by another bank after a shorter period. how we handle your data is less relevant than the question of how long a supporting document remains valid elsewhere; the receiving party determines that, not your own record-keeping.
What this means in practice
For most SMEs that supply foreign customers occasionally or structurally, this amounts to something extra: one or two additional documents, a translation, or slightly stricter control of who within your company has signing authority. It is no reason to assume that you are doing something wrong; it is a consequence of how directives work in the European Union.
Whether a specific customer in a specific country asks more of you than you are used to, you can best inquire with that customer themselves or with the supervisory authority in that country. For a first impression of what applies to your type of business and your sales market, you can in a few questions see which questionnaires may apply to you.
Supplia.eu explains nothing and does not assess any file; we help you keep the answers and supporting documents you already have well organised for the questionnaires that come your way. If you want to know exactly how that works, please read how the information on this platform is created, or view the answers to the questions we receive most often.