A 3-month campaign of disclosing end beneficiaries of ukrainian enterprises starts on July 11 – what to do?

The Ministry of Finance reminds that on July 11 the campaign of disclosure by business entities of their ownership structure and final beneficiaries will begin. Thus, on July 11, 2021, the Regulation on the form and content of the ownership structure, approved by the order of the Ministry of Finance dated 19.03.2021 № 163, comes into force. Despite the old date, it was registered by the Ministry of Justice only on June 8 and published on June 11. This order obliges all Ukrainian companies to provide the relevant information to the state registrar in order to establish their end beneficiary (owner or owners).


In turn, the Ministry of Justice informs that all legal entities, entrepreneurs and public associations which are registered before 08.06.2021, need to submit information confirming their end beneficiaries to the state registrar within three months starting from 11.07.2021. The following documents need to be submitted:


–       application for state registration of a legal entity


–       ownership structure in form and content in accordance with the Order on ownership structure;


–       extract or other document confirming the registration of a non-resident legal entity in the country of its location – if the founder of the Ukrainian legal entity is a non-resident legal entity;


–       a notarized copy of the document certifying the identity of the end beneficiary in case they are a physical person.



The administrative fee for this procedure will not be collected if the state registrar is provided with information on end beneficiaries as specified by the Law on Registration within the established deadline.


The Ministry of Justice pointed out that the information on end beneficiaries can prepared in any form and should be a schematic representation of all persons who directly or indirectly own the legal entity independently or jointly with other persons. The ownership structure should indicate the size of the participation of each of the owners, as well as indicate the persons who, regardless of formal ownership, have the opportunity to significantly influence the management or activities of the legal entity. In addition, it is necessary to indicate a description of the nature of the influence of the end beneficiaries on the activities of the legal entity. Samples of the schematic representation of the ownership structure can be found on the official website of the Ministry of Finance.


Note that failure to submit the necessary documentation or their late submission entails a fine on the head of the legal entity or a person authorized to act on behalf of the legal entity, from 17,000 to 51,000 UAH (approximately 500 – 1500 euro).

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