By Yusra Sarkar


Last summer, the Luxembourg authorities extended the original August deadline to have all information for entities that had not yet filed the details of their beneficial owners (‘BO’) in the country’s Beneficial Ownership Register. Entities could submit the details of the BO(s) to the relevant authorities until the end of November without the risk of sanctions. The country’s UBO register is now live.

‘The November extension was welcomed by some entities while their UBO’s compiled and sent data to the authorities. That said, the vast majority of ZEDRA Luxembourg’s clients had registered their BO details comfortably ahead of the initial August deadline,’ says Frank Walenta, Commercial Director, ZEDRA Luxembourg.

Now that the UBO register is live in Luxembourg, it has allowed the general public and other interested parties like bankers, lawyers and notaries to see how it works in practice. It has also shed light on how the Luxembourg authorities are tackling requests for UBO’s who wanted to keep their details off the public register – usually for factors relating to material risk. Luxembourg doesn’t allow for an exemption on providing the authorities with relevant UBO information, but in some instances, they could allow a UBO’s details to be anonymous on the public register. Around 1,600 requests for a UBO’s details to remain anonymous in the public register have been submitted to the Luxembourg authorities. Of these, some 450 have been ruled on so far.

‘So far, the authorities have approved requests for anonymity where the UBO is either a minor or can evidence that there are material risks to his / her personal safety. We expect this to continue but at the same time, we are seeing a definitive trend towards authorities not accepting requests for public UBO anonymity based on most other factors,’ says Frank.


In late December the Upper House of the Dutch Parliament announced that it had voted to delay the implementation of the legislation which would have brought the UBO register into force on January 10th 2020. It is now expected that the UBO rules will enter into effect later in the spring – most probably late April

‘Despite the delay, the topic of the UBO register in the Netherlands is nothing new, and we’ve been liaising with our clients on this for some time already. When the legislation is implemented, our clients know what to expect and how we can support them in the process of staying compliant with the new regulations,’ says Tako van Ginkel, Managing Director ZEDRA Netherlands. ‘When it comes to registering their details later this year, we will be supporting clients on a case by case basis, acting as a trusted partner in the Netherlands to facilitate the necessary registration, when the legislation enters into force,’ says Tako.

For more information, please contact Frank Walenta, Commercial Director, ZEDRA Luxembourg or Tako van Ginkel, Managing Director ZEDRA Netherlands