Listed companies and the UBO register: not always an exemption!


In previous news flashes we already informed you about the implementation of the UBO register, the extension of the deadlines and the updates of the Frequently Asked Questions (FAQ).

In the updated version of the FAQ published on 19 July 2019 the Belgian authorities stated that listed companies are exempted from registering their UBO’s if they are subject to transparency requirements consistent with Union law or equivalent standards (according to what already was foreseen by the Fourth Anti Money Laundering Directive).

As it was not totally clear to which listed companies this exemption applies (100% or partially listed, Belgian subsidiaries of foreign listed companies, …), the Belgian Authorities published an amendment to this FAQ on 26 Augustus 2019.


This amendment includes that:

  • Belgian listed companies are exempted from registering their UBO’s, whether their shares are 100% or partially listed;
  • Belgian subsidiaries of a (Belgian or foreign) listed company are only exempted from registering their UBO’s if their shares are 100% held by the listed company (directly or indirectly). If not, the normal rules apply and the Belgian subsidiary will have to identify its UBO’s and register their information to the UBO register.

As a consequence, listed companies should consider the minority shareholders of their Belgian subsidiaries in their corporate structure, to conclude whether or not the UBO’s of their Belgian subsidiaries should be registered to the UBO register.

If you have any question with regard to this matter, please reach out to your regular PwC advisor or contact Stefan De Plus.