A new company has 90 days to file a UBO. This is a mandatory formality.

Establishing a company is just the beginning of the formalities. After registration, entrepreneurs must remember to register their ultimate beneficiary (UBO) in the electronic register. This obligation must be fulfilled within 90 days from the date the company is entered in the register.

Failure to report or to comply with subsequent obligations may result in financial sanctions and difficulties in contacts with banks and other institutions.

What is the UBO register?

The Ultimate Beneficial Owner Register (UBO) is used to identify individuals who actually control or benefit from a company. The obligation to report beneficial owners arises from anti-money laundering (AML) and counter-terrorism financing regulations.

For most newly established companies, this is one of the first formalities after obtaining a registration number (HE Number).

How to register a beneficial owner?

The procedure consists of several stages.

First, you must create an organization profile in the CY Login system, which allows you to use electronic government services. Then, the profile must be verified and associated with a specific company.

Only after authorization is completed is it possible to log in to the UBO Register system and provide information about the beneficial owner.

The company has 90 days from the date of registration to complete the entire procedure.

It is not worth postponing the formalities

While the deadline may seem long, it's worth starting the process as soon as possible. Creating and authorizing a profile in the CY Login system may take additional time, which in practice shortens the time available for submitting an application.

Completing the formalities in advance also helps avoid problems when dealing with subsequent matters related to the company's operations.

Why is UBO reporting important?

The information contained in the UBO register is used by banks and financial institutions as part of AML (anti-money laundering) and KYC (Know Your Customer) procedures.

Current data may be important, among other things, when:

• opening a bank account for the company,
• use of financial services,
• verification carried out by contractors,
• controls performed by auditors and advisors.

The lack of current data may prolong some procedures or make them more difficult to carry out.

The obligation does not end with the first notification

Entry into the UBO register is not a one-time activity.

Every company is required to annually confirm the validity of its data, even if the ownership structure has not changed. Additionally, any changes regarding the beneficial owner, shareholders, or ownership structure must be reported in accordance with applicable regulations.

Penalties may be imposed for failure to fulfill obligations.

The regulations provide for the imposition of financial sanctions for failure to comply with UBO register obligations. The amount of the fines depends on the nature and duration of the violation.

Therefore, entrepreneurs should remember not only about the first notification, but also about timely updating of data.