UBO register Belgium — filing, confirmation and access
Belgium is the EU register that asks you to prove it, and then asks you again every year. The UBO register run by the FPS Finance Treasury Administration is not a one-off filing. Since October 2020 every beneficial owner recorded there must be backed by a document showing the entry is adequate, accurate and current, and the whole file has to be confirmed annually whether anything changed or not. Miss both for long enough and the entity picks up a striking-off mention in the Crossroads Bank for Enterprises — and since the end of April 2026, that mention no longer lifts by itself.
1. Three instruments, and they do different jobs
Almost every practical question about the Belgian register resolves to one of three texts, and confusing them is how firms cite the wrong rule to a customer.
| Instrument | What it governs |
|---|---|
| Law of 18 September 2017, Articles 73–75 | Creates the register (Art. 73), names the entities that must file (Art. 74 §1), and imposes the substantive duty to hold and transmit adequate, accurate and current beneficial-ownership data (Art. 75) |
| Royal Decree of 30 July 2018 on the operating procedures of the UBO register | The field list, the access tiers, logging, control and sanctions. Published in the Belgian Official Journal on 14 August 2018, in force 31 October 2018 |
| Article 1:35 of the Companies and Associations Code | The filing clock for companies and associations — the source of the one-month rule the FPS portal expresses as 30 days |
Two amendments matter operationally: the Royal Decree of 23 September 2020 (in force 11 October 2020), which added the supporting-documents requirement, and the Royal Decree of 8 February 2023 (in force 17 February 2023), which rebuilt the third access tier after the Court of Justice struck down indiscriminate public access. A 2019-vintage guide to the Belgian register is wrong about both evidence and access.
2. Who files, and what Article 3 actually asks for
The obligation reaches companies, non-profit associations, international non-profit associations, foundations, trusts, fiduciaries and similar legal arrangements. FPS Finance publishes a spreadsheet of entity types in scope, worth checking before telling a customer it is exempt — the answer depends on the legal form recorded in the Crossroads Bank for Enterprises.
Beneficial owners fall into the three categories of Article 4, 27° of the 2017 Law: holders of more than 25% of the voting rights, shares or capital; persons who control by other means, such as a right to appoint or remove directors or a veto; and, only where the first two identify nobody, the senior managing officials. The FPS FAQ makes a point that trips up automated screening: a person can legitimately appear under the first category holding less than 25%, because the category is about the nature of the interest, not only its size.
Article 3 §1 of the Royal Decree sets out sixteen data points for companies. Most are unremarkable — name, day, month and year of birth, nationalities, country of residence, full residential address, the date the person became a beneficial owner, a national identification number or foreign equivalent. Three are not, and these are the ones to read the extract for:
- Point 13°: direct or indirect. The register distinguishes them, so an extract tells you which chains the entity says exist.
- Point 14°: every intermediary, fully identified. Corporate name, date of incorporation, trade name, legal structure, registered-office address and enterprise number for each intermediary in the chain.
- Point 15° b): weighted percentages. For an indirect beneficial owner, the filing must state the percentage of shares and weighted voting rights held or controlled at the filing entity and at each intermediary. This is the field that reconciles a customer’s ownership chart against the register line by line.
3. Two clocks, and only one of them is event-driven
Belgian filers run two independent obligations that fail separately. The first is the 30-day clock: register the beneficial owners within 30 days of incorporation, and update within 30 days of any change, in the entity or in the beneficial owners themselves. This is the clock everyone knows about.
The second is the annual confirmation. Article 5 of the Royal Decree requires the data to be updated by electronic means at least annually, and the portal implements this as a dedicated Annual confirmation button. Nothing needs to have changed. An entity stable for six years still owes six confirmations, and a file that is factually correct but unconfirmed is non-compliant. FPS Finance runs an e-mail reminder and a newsletter for exactly this reason, which tells you how often it is missed.
4. Getting in without a Belgian eID
The filer authenticates with a Belgian identity card, itsme or an eIDAS means, selects the option to act in the name of a company, searches the entity, opens its UBO file and edits it. Supporting documents attach in their own section of the same file.
This is where cross-border structures stall. Three ways through:
- ForREG. The Foreign Registration application issues credentials to people with no Belgian authentication means — normally the route for a non-resident director.
- Appoint a legal representative who holds a Belgian eID.
- Give a mandate through the Mandates application, so an accountant or another entity administers the register.
A paper mandate procedure exists but FPS Finance narrowed it on 24 June 2026, and the restrictions are absolute: a proxy giver holding a digital key — eIDAS or ForREG — cannot use the paper route at all, and one who already has two active UBO mandates and wants to change proxy holder must log into the Mandates application personally. An entity with no legal representative on file must fix that first.
5. Reading the register as a reporting entity
Article 6 of the Royal Decree opens the data — current values and the history of changes — to three populations: competent authorities, in good time and without restriction; reporting entities, in due time and within the framework of their customer due-diligence obligations; and, since 17 February 2023, any natural or legal person who can demonstrate a legitimate interest. The second tier is the one an EMI or payment institution uses, and it is a due-diligence permission rather than a general search right.
Two features of Article 15 shape how the consultation should be documented. Under §1, consultations happen without informing the entity or the beneficial owners — so a register check is not a tipping-off risk. Under §2, every consultation is recorded and retained for ten years. Your access leaves a durable trace on the supervisory side, which is an argument for consulting the register as a standard onboarding step: a file with no consultation now looks like a choice.
Since January 2026 FPS Finance has documented BORIS, the Beneficial Ownership Registers Interconnection System, in its manuals for reporting entities and supervisory authorities. BORIS links the national beneficial-ownership registers of the Member States and lets competent authorities and reporting entities search, view and download beneficial-ownership data held in other national registers — for a firm passporting into several markets, one access route plus a routing decision instead of six.
6. Sanctions, striking off, and the April 2026 change
Article 18 §1 of the Royal Decree lets the Minister or a delegate impose the administrative fines of Article 132 §6 of the 2017 Law for breaches of Articles 3 to 5 — the data, the trusts provisions and the annual update. The FPS FAQ states the range as €250 to €50,000, and where a fine goes unpaid for 60 days a striking-off procedure may follow.
The striking-off mention is the sanction that bites, because it is visible to every counterparty pulling the entity’s Crossroads Bank record. On 17 June 2026 FPS Finance published a procedure change with a firm date attached: since the end of April 2026 the withdrawal of the striking-off mention is no longer automatic. The entity must first bring itself into compliance — correct registration, supporting documents, annual confirmation where applicable — and then e-mail FPS Finance to request withdrawal. An official reviews the file and, if it is in order, the mention comes off within a maximum of ten days.
7. Three files, three outcomes
The rules above decide real onboarding decisions in ways that are not obvious from the text.
Scenario one — the extract that does not match the chart. A Belgian operating company applies for a business account. Its ownership chart shows one individual at 41% through a holding company. The UBO extract records the same person as an indirect beneficial owner, but point 15° b) shows 41% of shares and 62% of weighted voting rights, because the holding company’s stake carries double voting rights. Rule: Article 3 §1 15° b) requires the weighted figure at the entity and at each intermediary — the register is not wrong, the customer’s chart is incomplete. Action: record control at 62%, and take the constitutional document creating the double voting rights as evidence. Outcome: the file reflects control rather than economics.
Scenario two — the customer who says it has been fixed. An existing customer’s Crossroads Bank record shows a striking-off mention for UBO non-compliance. The customer replies that it filed last week and the mention will disappear. Rule: since the end of April 2026 withdrawal is not automatic; the entity must request it by e-mail after achieving compliance, and FPS Finance then takes up to ten days. Action: treat the filing and the withdrawal as two separate events, ask for the date of the withdrawal request, and diarise a re-check at day ten. Outcome: the review closes on an observable state rather than on a promise.
Scenario three — nobody can log in. A Belgian subsidiary of a non-EU group has two directors, neither resident in Belgium and neither holding an eID or itsme. The group asks whether the paper mandate form will work. Rule: the paper procedure is closed to a proxy giver holding eIDAS or ForREG credentials, and closed for a proxy-holder change where two mandates are already active. Action: route the directors to ForREG first, and record a legal representative if none exists. Outcome: the 30-day clock is met through the channel that exists for the structure, rather than expiring while a paper form is in the post.
FAQ
How long does a Belgian entity have to file?
Thirty days from incorporation, and thirty days from any change in the entity or its beneficial owners. The underlying rule for companies and associations sits in Article 1:35 of the Companies and Associations Code and is expressed as one month; the FPS Finance portal states it as 30 days.
Is the annual confirmation really required when nothing has changed?
Yes. Article 5 of the Royal Decree of 30 July 2018 requires the information to be updated at least annually, and the portal implements this as a separate Annual confirmation action. A correct but unconfirmed file is non-compliant.
What counts as a supporting document?
Anything that demonstrates the registered information is adequate, accurate and current — a copy of the share register, minutes of the general meeting, a shareholders’ agreement. Where the information appears in a deed published in the Belgian Official Journal, the file can be linked to that publication instead. FPS Finance expanded its FAQ guidance on acceptable documents in January 2026.
Can we search the register as a foreign payment institution?
Article 6 2° opens the register to reporting entities within the framework of their customer due-diligence obligations. Cross-border, the route documented since January 2026 is BORIS, which lets reporting entities and competent authorities search, view and download beneficial-ownership data held in other Member States’ registers.
Will the customer know we looked?
No. Article 15 §1 requires the Treasury Administration to ensure that consultation happens without informing the filing entity or the beneficial owners. Article 15 §2 requires every consultation to be recorded and kept for ten years.
What are the penalties?
Administrative fines under Article 132 §6 of the Law of 18 September 2017, applied through Article 18 §1 of the Royal Decree for breaches of Articles 3 to 5; the FPS FAQ states a range of €250 to €50,000. Non-payment after 60 days can trigger a striking-off procedure recorded in the Crossroads Bank for Enterprises.
How does an entity get a striking-off mention removed?
Since the end of April 2026, not automatically. The entity must first be compliant — correct registration, supporting documents uploaded, annual confirmation done — then e-mail FPS Finance to request withdrawal. An official checks the file and, if it is in order, the mention is withdrawn within a maximum of ten days.
8. What to do, today
- Check the annual confirmation date, not just the filing date. They are different obligations and only one is event-driven. A recent extract tells you nothing unless the confirmation was part of it.
- Reconcile against point 15° b), not the headline percentage. The weighted voting-rights figure at each intermediary is where a control position diverges from an economic one.
- Treat a missing supporting document as a defect. Since 11 October 2020 it is part of what Article 3 requires.
- Record the consultation in the customer file. Article 6 2° makes the access a due-diligence permission, and Article 15 §2 logs it for ten years anyway.
- Decide whether BORIS replaces your national access routes. The alternative is maintaining a Belgian authentication chain you will use rarely.
- Put a ten-day re-check on any striking-off remediation. The withdrawal is a separate request, and the mention stays visible until it completes.
Related: Beneficial ownership registers — filing and discrepancies · Discrepancy reporting on UBO registers · CTIF-CFI and goAML — reporting suspicions in Belgium · What is a beneficial owner
