Disclosure of information on the UBO


On 28 April 2020, new legislative requirements to the disclosure of information on company’s ownership structure will come into force. To increase the transparency of business, the new Law #361-IX (dated Dec 6, 2019) will provide novelties for companies registered in Ukraine, including those for their ultimate beneficial owners (the “UBO“).

The essential novelties are the following:

>> A company should submit documents on ownership structure during the state registration

During the state registration of the company (including its establishment, amendments to any information on the company in the Ukrainian corporate register), the company should submit the following documents to a state registrar:

  • the company’s ownership structure;
  • an extract or any other document, which confirms the registration of the company’s participant (if such a participant is a foreign company);
  • certified copy of a document identifying an individual which is the company’s UBO.


If no UBO’s change has occurred, the company applying for the registration of any amendments is obliged to inform the state registrar on the absence of such changes.

The Law also specifies the possibility to declare the UBO’s absence with a justified reason for the non-availability. The company’s ownership structure should confirm this absence as well.

The form and content of such an ownership structure will be further approved by the government bodies. Existing companies must disclose their ownership structure and information on the UBO to a state registrar within three months from the date of entry into force of the legislative act, which approves the form and content of the ownership structure.

>> The company should confirm and update information on UBO

The company should submit an application and the documents specified above on an annual basis to confirm the information on the UBO.

Additionally, the company is obliged to keep the information on the UBO and its ownership structure updated. Thus, the company should notify the state registrar of any of the above changes within 30 business days from their occurrence, as well as to submit documents confirming these changes.

>> The company’s management is liable for non-submission of information on UBO

Failure to submit the information on the UBO / the UBO’s absence or the document confirming the above information to the state registrar may result in the fine up to UAH 51,000 (approx. EUR 2,000) imposed on the company’s chief executive officer.

To comply with the Law, we recommend each existing company to consider the above changes, as well as to duly submit the information on the UBO and the company’s ownership structure to the state registrar.



Should you have any questions, please contact Partner and Head of Corporate and M&A at INTEGRITES Illya Tkachuk: Illya.Tkachuk@integrites.com.