The introduction of the UBO register: postponed again

The Dutch Ministry of Finance has announced that the regulation regarding the mandatory registration in the UBO register will be postponed once again. A temporary regulation was previously introduced, allowing companies who had submitted their UBO declaration to the Chamber of Commerce, but whose declaration had not yet been processed, to temporarily suffice with an acknowledgment of receipt of the UBO declaration. For instance when a company needs to prove to a financial institution that the UBO registration requirement has been met. This temporary rule has now been extended until 1 January 2023.

The temporary regulation was introduced because of the long processing time at the Chamber of Commerce, as was explained in a Parliamentary Letter dated 14 April 2022. Because of the fact that many companies submitted their UBO declaration to the Chamber of Commerce on or shortly before the final date of 27 March 2022, the Chamber of Commerce was faced with a large backlog. The turnaround time for a UBO declaration is currently about 25 weeks.

The extension of the temporary regulation only concerns the confirmation of receipt of the UBO declaration. The extension of the term expressly does not concern the obligation of companies to register their UBOs. This obligation applies in full as of 27 March 2022. Only if a company has submitted its UBO declaration on or before 27 March 2022, but the registration has not yet been processed in the UBO register due to delays at the Chamber of Commerce, the confirmation of receipt of the UBO declaration will suffice up to 1 January 2023.