Important update from the Crossroads Bank for Enterprises (CBE): a new procedure is in place for ex officio striking off company registration numbers. What does this mean for you? Let's break it down.
What has changed?
The CBE management service now has the authority to strike off entities that have not met their obligations for entering or updating data in the register of ultimate beneficial owners (UBO register). Here are the criteria for these strikes:
- Entities that have not provided UBO information within 60 days after receiving an administrative fine (due to lack of/incorrect UBO registration).
- Entities that fail to confirm their UBO registration annually.
- Entities that fail to provide UBO information and have not published anything other than annual accounts in the Belgian Official Journal for seven years
In action
This new procedure is already in effect. In the first round, nearly 21,000 legal entities felt its impact. Another 8,000 will follow in a second wave.
What happens next?
If your entity gets struck off, you will need to fix the problem to reactivate your registration. For UBO-related strikes, this means providing all missing information. It is worth noting that an administrative striking off does not dissolve the entity. It retains its rights and obligations.
Why it matters
This measure helps identify dormant or ghost companies. Compliance with UBO regulations is crucial for all Belgian entities, nonprofits, foundations, and their directors.
How we can help
Do you have questions about UBO regulations or the ex officio strike-off process? Our team of experts is here to support you. Do not hesitate to reach out to us.
Stay compliant and stay informed!
Key contacts
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 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.
