UBO disclosure obligation for legal entities


As of September 1, 2018 almost all legal entities are required to disclose their actual beneficiaries in the Estonian Centre of Registers and Information Systems. Legal entities already registered in the register must provide the actual beneficiaries by 31 October 2018 at the latest.

Further, KPMG’s Global Legal Services has launched a publication on the Ultimate Beneficial Owner (UBO) disclosure requirements within the EU. This publication provides an overview on the current status quo of the implementation of the 4th AML Directive, especially the different requirements to identify and register UBOs in various EU member states and Switzerland. Across Europe companies are required to comply with the new regulations and non-compliance with the new laws may result in substantial fines in various member states.

In Estonia the sanction for not filing data, or filing incorrect data, on a beneficial owner is a fine up to EUR 1,200 for a natural person and a fine up to EUR 32,000 for a legal person. The sanction for not conducting identification procedures is a fine up to EUR 1,200 or detention for a natural person and a fine up to EUR 400,000 for a legal person.

We have put together a team of specialists to assist our clients with their UBO registration requirements. In close cooperation with our colleagues, we can navigate you through the very latest legislation and assist you in making the necessary filings to the competent authorities.

Subject to disclosure are the name of the UBO, birth date, state of residence and the nature of the beneficial interest held. The management board is responsible for forwarding the data to the Commercial Register.

For additional or other legal questions, feel free to contact our team at KPMG.

More information:

Karin Kaup (Oras)
Partner / Attorney-at-Law
Tel +372 667 6805
Mob +372 507 9241