What is the Dutch UBO register, and what does a foreign parent need to file?

Every Dutch BV files its ultimate beneficial owners with the KvK, the Dutch Chamber of Commerce. A beneficial owner is always a person, never a company: someone who holds more than 25% of the shares or the votes, directly or through companies above. A parent company abroad does not file its own owners here, but its owners appear in the Dutch filing.

UBO stands for ultimate beneficial owner. Every country in the European Union keeps a register of them, because anti-money-laundering rules require it. In the Netherlands the register is kept by the KvK, and for a BV the civil-law notary files it at incorporation.

For a founder whose company is owned from Korea, Japan, Taiwan, Singapore, Türkiye or the United States, the register is the moment the ownership of the whole group has to be written down and proved. That is worth preparing, because the same chain comes back at the bank and again during investor due diligence.

Who counts as a beneficial owner when the parent is abroad?

According to the Dutch decree that implements the anti-money-laundering act, a beneficial owner of a BV is a natural person who directly or indirectly holds more than 25% of the shares, more than 25% of the voting rights, or an ownership interest above that level, or who has control by other means. Nationality and country of residence make no difference.

Indirect is the word that matters for a group. If a person holds more than a quarter of the parent company, and the parent holds the Dutch BV, that person is a beneficial owner of the Dutch BV. The chain is followed upwards through as many companies as it takes until it reaches people. A company is never the answer, only the route to it.

Sources:
Uitvoeringsbesluit Wwft 2018, article 3 (wetten.overheid.nl)
Business.gov.nl, UBO register for ultimate beneficial owner

What if nobody owns more than a quarter?

Then the company files its senior management instead. The same decree says that when every reasonable effort has been made and no beneficial owner can be found, or when there is doubt whether the person found is really the ultimate owner, the natural persons who belong to the senior management are recorded. In a BV that means its statutory directors.

This is common for a startup after a few rounds, where no single shareholder is left above the threshold. It is not a loophole and it is not a failure: it is the rule the register was built with. The company still has to show that it looked properly, which is why the notary asks for the full shareholder picture even when the answer turns out to be the board.

Source: Uitvoeringsbesluit Wwft 2018, article 3 (wetten.overheid.nl)

Does the parent company register its own owners in the Netherlands?

No. Foreign legal entities, such as a Korean, Japanese or German company, do not register their beneficial owners in the Dutch register. They do that in the register of the country where they were formed. A foreign company that only has a branch office in the Netherlands does not file here either.

The Dutch filing belongs to the Dutch entity. Its beneficial owners are found by following the chain upwards, so the people behind the foreign parent do appear in it, even though the parent itself files nothing here. Whether a group opens a branch or a subsidiary therefore changes who files what, which is one more reason that choice comes first. It is set out in branch or subsidiary in the Netherlands.

Source: Business.gov.nl, UBO register for ultimate beneficial owner

What does the notary ask for?

Evidence of the chain, and evidence of the people at the end of it. In practice that means the deed of incorporation and articles of association of the companies above, their shareholder registers or their own register extracts, a chart of the group, and a copy of a valid identity document for each person who is filed.

Documents in other languages are usually translated, and foreign documents are often legalised so that the signature on them can be relied on.

After incorporation the duty stays with the company. Changes in the beneficial owners have to be reported within seven days of becoming official, so a new investor above the threshold, or a share transfer inside the group, is a filing and not only a board matter.

Sources:
Business.gov.nl, UBO register for ultimate beneficial owner
KVK, Register, change and deregister UBOs

Who can see what is filed?

Not the public. Access to Dutch UBO data is limited to the organisation itself and its own beneficial owners, to bodies with a legal task, and to the institutions that have to run anti-money-laundering checks. KVK lists those groups: the Tax Administration, the national police, the public prosecution service, the financial intelligence unit and Statistics Netherlands on one side, and banks, investment firms, civil-law notaries, accountants, lawyers and trust offices on the other.

That last group is why the register matters commercially. A bank that opens an account for a Dutch company can look at what the company filed, and it will notice when the filing and the paperwork tell different stories. The same is true of an investor's counsel later.

Source: KVK, Who has access to UBO data?

Getting it right once

The ownership chart a founder draws for the notary is the same chart the bank will ask for, and close to the one European investors will read. Doing it once, properly, saves repeating it three times: see opening a Dutch business bank account and what European investors check in due diligence. An extra Dutch company on top of the operating company lengthens that chart, and that trade-off is in the Dutch holding BV.

Sources

1. Uitvoeringsbesluit Wwft 2018, article 3, version of 4 February 2025 (wetten.overheid.nl, in Dutch), checked 22 September 2026
2. Business.gov.nl, UBO register for ultimate beneficial owner, checked 22 September 2026
3. KVK, Register, change and deregister UBOs, checked 22 September 2026
4. KVK, Who has access to UBO data?, checked 22 September 2026

Checked on 22 September 2026. This page is general information, not legal, tax or investment advice. Rules change: check the official source, or ask an adviser, before you act on it.