Board change? Adjust the UBO registration

Is there a change in the board of your vereniging (association) or stichting (foundation)? Or in the articles of association? Then be sure to check your UBO registration. If there are any changes, submit them to KVK within 7 days. Prevent a fine or troubles with your bank.

Do the UBOs change?

If the board of your vereniging or stichting changes, there may well be a change in the UBOs (Ultimate Beneficial Owners) of the organisation. UBOs are the persons who ultimately own an organisation, or are authorised to make decisions. For example, persons who own more than 25% of the organisation's assets or who are in the board of directors. If a person like that leaves the organisation as well as the board, they usually are no longer UBOs.

Changes in the articles of association can also have consequences for determining who are your organisation's UBOs. For example, if the minimum number of board members changes. 

So, whenever there is a board change or a change to the articles of association, remember to check the UBO registration. You can use the confirmation letter you received when you registered your UBOs to see who has been registered. 

Stichtingen and verenigingen have to register UBOs

All stichtingen (foundations) and verenigingen (associations) have to register UBOs. There are 2 exceptions to this rule. These types of vereniging do not have to register UBOs: 

  • A vereniging with limited legal capacity, without a business purpose.
  • A vereniging van eigenaren (VvE, Owners' Association).

Do you convert your vereniging into a vereniging with full legal capacity at a civil-law notary's office? Then the civil-law notary will take care of the UBO registration for you. 

Risk of incorrect UBO registration

You have to report changes in your UBO registration within 7 days. The Bureau Economische Handhaving (Economic Supervision Bureau, in Dutch) checks the registrations and imposes fines when the details are not correct. 

Banks check your business as well and will ask about the UBOs of your vereniging or stichting. If the bank finds a difference between the UBOs you list and the ones registered with KVK, they may block your organisation's bank account. 

How to change UBOs

Prepare well, so you can change the UBOs in one go. You report changes for your stichting or vereniging in your UBOs with the UBO report

Important: you have to report a board change of your vereniging or stichting in the KVK Business Register as well as in the UBO register. You have to submit the changes for both registers within a week after the board change.