Don't forget the annual UBO register obligation!
March 2026 - As an SME entrepreneur, you have your hands full every year with closings, tax returns, and strategic plans. In that daily stream of obligations, one formality can easily slip through the cracks: the annual confirmation of the UBO register. This is a legal obligation that you should comply with accurately.
What exactly is the UBO register?
UBO stands for Ultimate Beneficial Owner, i.e. the ultimate beneficiary of an organization. These are the natural persons who directly or indirectly exercise control over a company, non-profit organization, foundation, or other legal entity. This can be through share ownership, voting rights, or a specific management position.
Through the UBO register, the FPS Finance collects information about who is actually “behind” an organization. This database provides transparency about who is in control and how the ownership structure is organized.
This register, introduced in 2028, is not a non-binding administrative exercise. Its objective is to combat financial fraud, money laundering, and shady constructions. Transparency about ownership is essential in this regard. Do you have a Belgian legal entity? Then you are obliged to register your UBOs correctly and keep that information up to date.
Even if there have been no changes, you must still confirm
A persistent misconception is that you only need to take action when there is a change in your shareholder structure or management. This is not correct.
Even if there have been no changes in the past year, you must explicitly confirm that the registered data is still accurate and complete. This annual confirmation is a separate legal obligation.
Failure to do so may result in administrative fines ranging from €250 to €50,000. This is not a detail to be taken lightly, especially for SMEs that want to ensure their compliance is in order.
When do you need to take action?
The deadline for your next confirmation depends on the date of your previous validation. For example, if you confirmed on March 15, 2025, the next confirmation must be made no later than March 15, 2026.
You can easily find this date via MyMinfin. After logging in, go to your UBO registration files and consult your company's file. There you will see the latest date for the next confirmation for each entity.
If you work with multiple companies or mandates, it is best to check this for each entity separately. After all, a missed date can quickly lead to an unpleasant surprise.
How does the confirmation process work in practice?
The procedure is entirely digital. You log in via MyMinfin using your eID, itsme, or another recognized access method. Next, you select the correct entity, open the UBO file, and thoroughly check all the registered data.
Is the data still correct? Then click on “annual confirmation” at the bottom. Afterwards, download or save the confirmation document. It is advisable to also send this to your accountant so that your file remains complete.
Do you use a digital securities register such as eStox? In some cases, the UBO confirmation is processed automatically via that system. Nevertheless, it is wise to explicitly coordinate this with your accountant or file manager. Automation does not relieve you of your responsibility.
Small effort, big peace of mind
The annual UBO confirmation takes little time, but prevents potentially heavy penalties. By checking in good time when your next confirmation is due and following the procedure correctly, you avoid unnecessary fines and remain administratively compliant.
Are you unsure about the correct registration or do you have questions about your specific situation? Be sure to consult your accountant. This will keep your business on track, not only financially but also legally.
