Step 2 of 5

Who are the UBOs in your organisation?

In a foundation (stichting), several interests may be at stake. Based on these interests, you as an organisation determine who are the UBOs.

Who are the stakeholders in your organisation?

These persons can be designated as UBOs. If your foundation has a maximum of 3 beneficiaries, then these persons are all UBOs. Make a note for which percentage of the capital the UBO is a beneficiary:

  • over 25%, and less than or equal to 50%
  • over 50%, and less than or equal to 75%
  • over 75%, and less than or equal to 100%


Foundation Help Y has raised money for Ms Y, who needs to undergo surgery. This has been registered as the aim of the foundation in the target description. Mrs Y is the only person for whom funds are being raised. Therefore, Mrs Y is the beneficiary of the capital, and the UBO of this foundation.

Persons who have over 25% of the voting rights in the organisation can be designated UBOs. It concerns voting rights for statutory amendments, if the articles of association allow it. Make a note of the percentage of the UBOs’ voting rights:

  • over 25%, and less than or equal to 50%
  • over 50%, and less than or equal to 75%
  • over 75%, and less than or equal to 100%


Foundation Q has 3 directors, each of whom has one vote, which is 33.3% of the votes. These directors may - on the basis of the articles of association - decide to amend the articles of association. In this example, all 3 directors are UBOs.

Foundation K has 3 directors: A, B, and C. Director A may cast 4 votes. Director B and C may both cast 1 vote. Director A is a UBO in this example, because they have voting rights for 4 out of 6 votes (66.6%). B and C both have voting rights for only 16% of the votes, and are therefore not UBOs in this example.

A foundation has 4 directors; each director has 1 vote. That means that each director has voting rights for 25% of the votes. None of the directors in this example is a UBO on the basis of voting rights, because none of them has voting rights for more than 25%.

If there are persons who have effective control, based on other circumstances than the ones mentioned above, you may designate these persons as UBOs.


Donor Z of interest group G finances the organisation. Z has no formal role in the organisation, but fulfils a role as external stakeholder. This makes Z a UBO in this example.

In that case, you register all managing directors as the organisation’s UBOs. You can only do so if these managers are registered in the Business Register as statutory directors. You do not register them on the basis of having a stake in the organisation, but because they have the function of director. This is often the case for foundations with ANBI status (Public Benefit Organisation).

You do not need to add any documents to the report to demonstrate their stake or interest.

Then choose the first interest that applies from the list on this page.

In that case, only the persons with more than 25% voting rights are your UBOs. 

Note: Persons with over 25% of the certificates issued by the STAK are not UBOs in the sense of beneficiaries of the capital. The STAK only functions as a type of 'distributor', because it is required to pay out any dividend it receives from its shares directly to the certificate holders. 

The certificate holders may still be UBOs of the STAK on the basis of their voting rights or effective control. 

On to the next step?

This page is part of the UBO report preparation pages. If you want to start over, you can go back to the starting page.