The Dutch UBO register in 2026 and 2027: what foreign shareholders of a Dutch BV need to know
Every Dutch BV must register its ultimate beneficial owners (UBOs) with the Netherlands Chamber of Commerce (KVK). For international entrepreneurs, two questions come up in almost every conversation: who can see my personal data, and what is going to change?
Both questions have new answers. Access to the Dutch UBO register is being restored step by step, a new framework for "legitimate interest" access is on its way, and the EU Anti-Money Laundering Regulation (AMLR) will bring further changes from July 2027. This article summarises where things stand on 28 October 2026.
Why access was restricted
The Dutch UBO register was originally partly accessible to the public. After the Court of Justice of the European Union ruled that general public access to beneficial ownership data was invalid, disclosure from the Dutch register was halted.
The Dutch legislator responded with an act restricting access to the UBO registers. According to the Dutch Senate's file on the bill, it was adopted on 8 July 2025 and published on 15 July 2025. It limits access to four groups:
authorities and obliged entities under the anti-money laundering rules, plus parties that can demonstrate a legitimate interest;
parties involved in sanctions compliance, supervision and enforcement;
public bodies that need UBO data for a statutory or EU-law task;
registered parties themselves, for their own data.
Who has access today
On 23 October 2026 the KVK updated its overview of who has access to UBO data. The key points:
Each UBO can view their own data, and each registered company can view its own UBOs.
Regulated professionals and institutions, such as banks and other financial institutions, lawyers, accountants and trust offices, regain access per sector. Only institutions that are objectively recognisable, for example through a licence or registration, are admitted.
Supervisors, the Dutch tax authorities, the Financial Intelligence Unit, the police and certain public bodies (including notaries) have access under specific rules.
Since the second quarter of 2026, digital UBO extracts with eHerkenning and a UBO API are available.
Access for authorities in other EU Member States will be phased in through the European interconnection of beneficial ownership registers.
What this means in practice: the general public cannot browse your UBO data, but the bank that opens your company account and the professionals involved in your transactions increasingly can.
What "legitimate interest" will mean
On 2 April 2026, the Dutch Minister of Finance sent a draft decree on access based on legitimate interest to Parliament. As summarised by Taxence, the draft provides that:
journalists, civil society organisations and scientific institutions face a lighter test;
(potential) contract parties and certain foreign authorities are assessed case by case;
the KVK decides within 12 working days, and access is granted for three years;
refusal is possible for lack of legitimate interest, risk of misuse or conflict with privacy rules.
The decree is still a draft. No entry-into-force date has been published.
What changes on 10 July 2027
The EU anti-money laundering package will largely replace the Dutch Anti-Money Laundering Act (Wwft) on 10 July 2027, when the AMLR starts to apply directly. Among the changes relevant to UBOs, as summarised by FBN:
The ownership threshold shifts from more than 25% to 25% or more. A shareholder holding exactly 25% will then qualify as a UBO on the basis of ownership.
The window for reporting discrepancies in the UBO register is extended from one week to fourteen days.
The Dutch term changes, which will show up in forms and documents.
In parallel, the new EU Anti-Money Laundering Authority (AMLA) finalised three technical standards on 1 October 2026, including one on customer due diligence: what information banks, notaries and other obliged entities must collect and verify, and how electronic identification may be used. Once adopted by the European Commission, these are proposed to apply six months after entry into force.
What foreign shareholders should do now
Check your registration. Make sure the UBOs of your BV are registered correctly and completely. Discrepancies reported by banks or professionals can lead to questions and delays.
Look at 25% holdings. If a shareholder holds exactly 25%, directly or indirectly, prepare for that person to qualify as a UBO from July 2027.
Keep your documentation ready. Expect banks and notaries to ask for certified identity documents, an ownership chart up to the natural persons, and evidence of the source of funds. Harmonised EU standards will make these requests more uniform, not lighter.
Review sensitive situations early. If disclosure of UBO data could create a personal risk, discuss the options with an adviser before data is requested.
Plan changes in your structure. Share transfers, new investors or changes in voting rights may change who qualifies as a UBO and trigger an update of the register.
How Corpexser can help
Corpexser guides international entrepreneurs through the incorporation and ongoing compliance of their Dutch BV, including UBO and KVK registrations. We coordinate with the civil-law notary and tax adviser where needed, so you have one point of contact for the full process.
Unsure whether your UBO registration is ready for 2027? Schedule an introductory call via corpexser.nl.
This article provides general information on the basis of sources available on 28 October 2026. It does not constitute legal or tax advice. Please contact us for advice on your specific situation.
