Who has access to UBO data?

19 December 2023
Edited 30 April 2024
3 min

Not everyone has access to the UBO register. Are you a UBO for an organisation? Then you can view your own UBO details. Organisations that have registered UBOs can also view their own UBO registration. In addition, several other organisations have access to the UBO register. For example, the Netherlands Tax Administration.

There are 3 access levels for the UBO register. The data that an organisation can view and download from the UBO register varies according to their access level.

Viewing your own UBO registration

As a UBO, you can view your own UBO data. Organisations with a UBO registration can also see which UBOs are registered for their organisation.

UBOs with shielded personal information

If a UBO is under 18 years old, under police protection, or under guardianship, the UBO can choose to have their personal information shielded. This is stated in Section 51b of the Commercial Register Decree 2008 (in Dutch). When the details of a UBO are shielded, organisations with level 1 access can only view the type and extent of the UBO's interest.

Search by person

Most organisations are only allowed to search the UBO register by an organisation’s name or KVK number. Some organisations are also allowed to search by person. This permits them to see directly with which organisations that person is registered as a UBO. These are organisations with access level 3. The only exception to this is Statistics Netherlands (CBS).

Access levels

These are the 3 access levels in the UBO register:

Access level 1: If the personal details of the UBO are shielded	Access level 1: If the personal details of the UBO are not shielded	Access level 2	Access level 3
Type and scope of the interest	Type and scope of the interest	Type and scope of the interest	Type and scope of the interest
	First name and surname	First name and surname	First name and surname
	Month and year of birth	Month and year of birth	Month and year of birth
	Country of residence	Country of residence	Country of residence
	Nationality	Nationality	Nationality
			Date of birth
			Place of birth
			Country of birth
			Residential address
			BSN or TIN
			Copy of the documents that KVK has used to verify the details of the UBO
			Copy of the documents proving the interest of the UBO

Access level 1

These types of organisations have access level 1:

organisations such as chartered accountants, lawyers, and trust companies. Exactly which organisations these are, is stated in Section 1a of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), and in Section 51b (1) of Commercial Register Decree 2008 (in Dutch)
the Financial and Economic Affairs Department (DFEZ), as set out in the 2022 Recovery and Resilience Plan (in Dutch)
the Investment Screening Bureau (BTI)
organisations with a UBO registration (they only have access to their own UBO registration)

Access level 2

The organisations listed in section 51b (1) of the Commercial Register Decree 2008 (in Dutch) have access level 2. These include:

the organisations listed in Art. 1:1 of the Financial Supervision Act (Wft, in Dutch), such as:
- banks
- investment firms
- investment institutions
- electronic money institutions
- exchange institutions
- life insurers (except life insurers which are only in-kind funeral insurers)
- undertakings for collective investments in transferable securities (UCITS)
- financial service providers acting as life insurance intermediaries
- payment services agents
all types of civil-law notaries that fall under Section 1a(4)(d) of the Wwft (in Dutch).

Access level 3

These organisations have access level 3:

the Financial Intelligence Unit (FIU)
competent authorities listed in 51a of the Commercial Register Decree 2008 (in Dutch), such as:
De Nederlandsche Bank
Netherlands Authority for the Financial Markets
Financial Supervision Office
Netherlands Gaming Authority
Deans of the Bar Association
Netherlands Tax Administration
Minister of Finance
Fiscal Intelligence and Investigation Service
Justis
National Public Administration Probity Screening Agency (LBB)
National Police
National Police Internal Investigations Department
Public Prosecution Service
General Intelligence and Security Service
Military Intelligence and Security Service
Royal Netherlands Marechaussee
Social Affairs and Employment Inspectorate
NVWA Intelligence and Investigation Service
Human Environment and Transport Inspectorate
Statistics Netherlands (except for copies of documents used by KVK to verify the UBO's details, and of the documents showing the UBO’s interest)

Temporarily no access

At the moment, organisations with access level 1 and 2 temporarily do not have access to the UBO register. Therefore, these organisations are currently still asking businesses, foundations, and associations to provide an overview of registered UBOs themselves.

Amendment Act

Access to the UBO register may change due to changes in law. Follow changes to current laws and regulations via wetten.overheid.nl (in Dutch).

A legislative proposal is currently pending that will expand access to UBO registers. Read more about this proposed legislative change (in Dutch).