What is a UBO?
A UBO (Ultimate Beneficial Owner) is any natural person who ultimately owns or controls a legal entity. Under Dutch and EU anti-money laundering regulations, all companies must identify their UBOs and register them with the relevant authorities.
Who Qualifies as a UBO?
For a Dutch BV, a UBO is any individual who directly or indirectly holds more than 25% of the shares or voting rights, exercises effective control over the company (including through voting rights or other means of influence), or is the beneficiary of 25% or more of the company's assets.
If you're the sole shareholder and director of your BV, you are the only UBO.
If no individual meets the more than 25% threshold, a pseudo-UBO must be registered — typically a director or senior managing official of the company.
What Information is Required?
During BV incorporation through Neno, you'll need to provide the following for each UBO: full legal name, date of birth, country of birth, nationality, personal address (residential), and percentage of ownership.
For BVs with a single shareholder, this is straightforward — you only need to provide your own details. For multi-shareholder BVs, each person holding 25% or more must be registered.
UBO Registration with the KvK
The Netherlands requires UBO registration with the Chamber of Commerce (KvK). This is a legal requirement under Dutch AML regulations. Registration is handled as part of the notary process during your BV incorporation — you don't need to register separately. The information you provide in the Neno form is used for this registration. UBO information must be kept up to date after incorporation.
Identity Verification for UBOs
If you choose to open a business bank account, UBOs may need to complete identity verification (KYC) as part of the banking onboarding process. This is a separate step from incorporation and depends on the banking partner's requirements.
Frequently Asked Questions
Do I need UBO documents if I'm the only shareholder? For single-shareholder BVs, the document requirement is simplified — your identity verification covers UBO requirements.
What if no individual holds more than 25%? If no single person meets the 25% threshold, the senior management (directors) of the BV are registered as pseudo-UBOs.
Can UBO information be changed after incorporation? Yes, but changes must be filed with the KvK. UBO registration is a legal obligation and must be kept current.