What documents do you need for your UBO registration?
When a customer, bank or insurer asks for proof of your UBO registration, it usually involves a fixed combination of documents: a current extract from the UBO register of the Chamber of Commerce, an organizational chart or ownership diagram showing how control in your business is structured, and a copy of the identity document of each ultimate beneficial owner. In the case of a foundation or trust, this is often accompanied by a deed of incorporation or trust deed, as this shows who the beneficiaries are.
The detail that is most often overlooked in this subject lies in that last document: the identity document. A copy of a passport or identity card almost always contains the citizen service number, and you should not simply share that number with a customer. If you do not redact it, you share more than is necessary for the purpose for which the document is requested.
What each document shows exactly
The extract from the UBO register shows who is listed as the ultimate beneficial owner in the official registration, including the nature and extent of their interest. You request this extract from the Chamber of Commerce and it is usually valid for a short period, as customers want to see that the information is current at the time of submission.
The organizational chart supplements that extract with the structure behind it: through which intermediate entities or cooperative arrangements the control runs. A customer uses this to verify that the UBO listed in the register logically aligns with the legal structure of your business. For a simple sole proprietorship or a private company with one shareholder, this chart is brief; for a group with multiple layers, it may be more extensive.
The identity document serves to confirm that the person registered as the UBO actually exists and has the stated identity. This is the document that raises the most questions, because it contains personal data that falls under the GDPR.
Why the citizen service number deserves special attention
A passport or ID copy typically contains a passport photo, a signature and a citizen service number. For checking a UBO, that last number is usually not necessary: the name, date of birth and nationality are sufficient to make the link with the UBO register. Unnecessarily sharing a citizen service number touches on existing rules concerning personal data, and those rules applied even before questionnaires about UBOs became common practice.
In practice, this means that you can redact the citizen service number on a copy before you share the document, for example by making it illegible. Some KYC apps used by banks do this automatically when uploading; with manual submission to a customer, that step is up to you. More about the way personal data in such documents are handled, you can read on the page on the handling of your data.
Why a customer asks for precisely this combination
The request for UBO documents usually stems from the customer's own obligation to know their business relationships, a process often referred to in practice as Know Your Business or KYB. A bank or larger principal must be able to demonstrate that they know who they are doing business with, and the combination of extract, organizational chart and identity document is the standard way to substantiate this. That is also why these three documents recur with virtually every customer, even though the portal in which they are uploaded differs.
Because the same three documents are repeatedly requested, it is useful to prepare them once, completely and up to date, including the date on which the extract was obtained. An overview of what is requested where and why, you can find in the knowledge bank per topic.
What you can do with this
Whether your company currently fully complies with the registration obligation is something you can best verify with your Chamber of Commerce file or a lawyer; this article describes the documents, not your specific situation. If you first want an impression of which topics are relevant for your business, you can review that in a few short questions. Those who already have the documents in order and want to reuse them for multiple questionnaires at once can register with a business account to record them centrally.