UPDATE: Registration UBO postponed until 31 March 2019
As communicated in our previous newsflash regarding the Belgian UBO-Register, published on our website on 30 August 2018, Belgian corporate and other legal entities initially had to upload certain information on their UBOs to the UBO-Register by 30 November 2018 at the latest.
This deadline is based upon the obligation as provided for in article 14/1 of the Belgian Companies Code and article 58/11 of the Law of 27 June 1921 concerning the not-for-profit associations, the foundations and the European political parties and foundations stating that directors have to file the relevant information regarding the UBO(s) of their corporate entity within one month from the moment that information is known or has changed. Therefore, the initial deadline was fixed on 30 November 2018, i.e. one month after the date on which the Royal Decree of 30 July 2018 regarding the operating modes of the UBO-Register enters into force (31 October 2018).
However, the implementation of the online application for the UBO-Register has been delayed due to some practical obstacles. Therefore the FPS Finance has confirmed via its website that the first deadline for registration of the information regarding the UBOs has been postponed until 31 March 2019. Whilst the aforementioned initial deadline will not change, we have been informed that in practice, no (administrative) sanctions will be imposed until that date.
For further updates on this topic please consult this website or feel free to contact us for any advice and/or assistance.