Belgian UBO Register: how to verify beneficial owners

In brief

The Belgian UBO register lists the ultimate beneficial owners of all legal entities. Since 2018, domiciliation centers and other obligated entities must verify the UBO of every client before onboarding. Failure to verify exposes the center to a fine of up to 5 million euros and criminal prosecution.

Introduction: Mandatory UBO Register

Since 2018, all Belgian companies must declare their Ultimate Beneficial Owners (UBO) to the FPS Finance.

Who is a UBO?

Person owning > 25% capital/voting rights

Effective control (CEO, founders)

Consulting UBO Register

Via Company Belgium API

TypeScript

async function getUBOData(enterpriseNumber: string): Promise<UBOResponse> {
  const response = await companyBelgiumAPI.companies.getUBO(enterpriseNumber);
  
  return {
    ubos: response.data.ubos.map(ubo => ({
      name: class="code-string">`${ubo.firstName} ${ubo.lastName}`,
      ownershipPercent: ubo.shares,
      controlType: ubo.controlType,
    })),
    lastUpdate: response.data.registrationDate,
  };
}

Control Types

Type	Description
Direct	Ownership > 25%
Indirect	Via holding
Control	Decision power

Sanctions for Undeclared UBO

Company: €50 - €50,000

Domiciliation center without verification: €50k - €5M + 6mo - 5yr prison

Checklist

[ ] Consult UBO register

[ ] PEP screening

[ ] Sanctions screening (OFAC, EU, UN) under the Belgian AML Act 2017

[ ] Annual re-verification

[ ] Document results (10-year data retention)

Automate UBO verifications with Company Belgium API

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Related: Obliged Entities | AML sanctions Belgium

Frequently asked questions

What is the UBO register and who must be declared in Belgium?

The UBO register is a centralized database managed by FPS Finance that identifies the ultimate beneficial owners of all Belgian legal entities, operational since 2019. Any natural person holding directly or indirectly more than 25 percent of shares or voting rights, exercising effective control by other means, or holding the senior manager position as a last resort must be declared. Companies, non-profits, foundations and trusts are all subject to this obligation.

How do you verify the UBO of a Belgian company during AML due diligence?

UBO verification follows a sequential 3-step cascade: first shareholders holding more than 25 percent, then persons exercising control by other means, and finally senior managers as a last resort. Consultation of the Belgian UBO register on myminfin.be must be traced with date and PDF evidence. For complex structures with holdings, the ownership chain must be recursively traced up to the natural persons.

What sanctions apply if UBO is not declared or verified in Belgium?

For the company whose UBO is not declared, the administrative fine ranges from 50 to 50,000 euros, with possible bank account closure. For a domiciliation center that accepts a client without UBO verification, the sanction can reach 5 million euros under Article 91 of the Act of 18 September 2017, plus criminal prosecution for money-laundering complicity of up to 5 years' imprisonment.

How does the Company Belgium API help verify UBOs of Belgian companies?

The Company Belgium API allows cross-referencing BCE data with UBO information, automating PEP and sanctions screening for each beneficial owner, and calculating an overall risk score. For complex structures, it can recursively trace the shareholder chain. Each verification is timestamped to meet the 10-year retention obligation.