Posted: 09 Oct. 2023 2 min. read

End of tolerance period for non-compliant UBO registrations

Corporate and M&A | Legal Newsflash

Since the end of 2019, all Belgian companies, foundations and non-profit organizations are obliged to register their ultimate beneficial owners (UBOs) in the UBO register. Yet there are still many that have failed to register or have done so without fully complying with the regulations.

Obligation to register UBO information

The European Union, and by extension the Belgian Federal Public Service Finance (FPS Finance) consider the UBO register as a crucial tool in the fight against financial crime, including money laundering and terrorist financing. It has been implemented to promote transparency, help prevent illegal financial activities and strengthen the integrity of the financial system.

Despite the legal obligation and reminders from the FPS Finance, almost four years after the deadline for registration, more than 15,000 companies and more than 40,000 non-profit organizations and foundations still do not comply with the obligation to register their UBOs.

End of tolerance period

The FPS Finance initially took a flexible approach towards situations where entities subject to the UBO regulations had registered their UBO information but did not fully comply with the procedure. In practice this meant that a finding of an incorrect registration did not automatically lead to a penalty. However, the UBO website of the FPS Finance now clearly states that this “tolerance period” has ended with effect as from August 16th, 2023. Those who remain non-compliant with their UBO obligations risk significant fines. The FPS Finance has already issued 15,776 fines of 500 euros each for non-compliance with the registration obligation (up to now in case of a lack of any form of registration). These fines have raised more than 4 million euros to date.

Necessity of a correct UBO registration and the upload of supporting documents

It is essential for Belgian companies, foundations and non-profit organizations to properly maintain and monitor their UBO registration to avoid legal sanctions. This includes keeping the registered information up-to-date and providing relevant supporting documents to confirm the accuracy of the information.


As the tolerance period has ended, it is now more than ever in the interest of all Belgian companies, non-profit organizations and foundations and their directors to make sure that they comply with the UBO regulations. Besides keeping the registered information in the UBO register up to date, it remains equally important to upload the necessary supporting documents as they form an integral part of the registration.

As always, our committed team of experts is ready to support you with all your UBO queries. Do not hesitate to reach out to us with any queries you may have.

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Christoph Michiels

Christoph Michiels


Christoph Michiels joined the Corporate and M&A practice Deloitte Legal – Lawyers (previously Laga) in 2011. With over 20 years of experience in corporate transactional, advisory and restructuring work, he focuses on venture capital and private equity, assisting both founder and management teams as well as investors and investor syndicates throughout the different growth phases of start-ups and scale-ups. In this role Christoph leads the scale-up and investor initiatives within Deloitte Legal. Next to his corporate work, Christoph also heads the Deloitte Legal life sciences and healthcare practice which leverages Deloitte Legal’s multi-disciplinary expertise in corporate, commercial, regulatory, IP and data protection. He assists in particular biotech and medtech start-ups and scale-ups throughout their development process. In his role as head of the corporate compliance team, Christoph leads the corporate compliance practice of Deloitte Legal focusing on recurrent corporate secretarial work such as approval of annual accounts, replacement of directors, branch structures, etc. As such, he leads the legal entity management practice in Belgium and is in charge of the global roll-out of myInsight Entity Management (ELEMENT), a cloud based solution developed by Deloitte Legal for automated legal entity management. Christoph is the partner in charge of Innovation within Deloitte Legal and over the past few years, he has become a strong believer in digital transformation of the legal profession and is eager to share his experience with clients and building partnerships with legal tech providers with a view to contribute in future proofing the legal profession.

Filip Van Acoleyen

Filip Van Acoleyen


Filip is a members of Deloitte Legal’s Corporate and M&A team and heads the legal entity management team. Filip started his career with Deloitte, after which he transitioned to the law firm Laga to further develop the legal entity management offering. Filip has over 20 years of experience and is currently heading the Legal Entity Management practice at Deloitte Legal and responsible as such for the delivery and development of the LEM offering, he provides support to a wide-variety of companies, going from SME’s to large Belgian and multinational companies on corporate law, corporate practice and compliance matters. Filip has a general focus on legal technology innovation and is the product owner of the legal entity management tool myInsight Entity Management. Filip is a member of the Japanese Services Group at Deloitte and also supports the Legal Managed Services team within Deloitte Legal.