3. Beneficial Owners

When applying for changes to the register of shareholders of a limited liability company, information on the beneficial owners (BO) of the limited liability company must also be provided in the application form.

BO is a natural person who is the owner of a limited liability company or a person who exercises control over a limited liability company and is, at a minimum, a natural person who, through direct or indirect ownership, holds more than 25 per cent of the shares or voting rights in the limited liability company, or who otherwise exercises direct or indirect control over it.


Information on the BO of a limited liability company:

  1. name;
  2. surname;
  3. personal identity number (if the person has no personal identity number - the date, month, year of birth, the number of the personal identification document and the date of issue thereof, the country and body issuing the document);
  4. nationality (-ies);
  5. country of permanent place of residence;
  6. manner of exercising control over the limited liability company:
    1. through a status in the legal person (if the BO is a shareholder):
      1. as a shareholder;
    2. as a separate person who controls (if the BO is an indirect owner of, or exercises indirect control over, the limited liability company):
      1. on the basis of an authorization agreement;
      2. on the basis of ownership right (for example, if the BO is the owner of a legal person that is a shareholder of the limited liability company);
      3. through the legal arrangement as a founder;
      4. through the legal arrangement as an authorizing person;
      5. through the legal arrangement as a protector (if applicable);
      6. through the legal arrangement as a beneficiary or a category of beneficiaries;

      7. on the basis of a business relationship;

    3. other (free‑text field allowing the entry of an undefined manner of control);
  7. extent of control exercised;
  8. information regarding the person with whose intermediation the control is being exercised (to be provided where any of the methods referred to in subparagraphs 6.2 or 6.3 has been indicated as the manner of exercising control over the limited liability company):
    1. for a natural person: name, surname, personal identity number (if the person has no personal identity number - the date, month, year of birth);
    2. for a legal person (including a foreign legal person): name, registration number and legal address.

The Register of Enterprises is entitled to request documentary justification of the exercised control and also a document certifying the compliance of the information identifying the BO (a notarised copy of the personal identification document, a statement from a foreign population register, or other documents equivalent to the abovementioned documents) or documents justifying the certification that it is not possible to determine the BO.

The right to request the above-mentioned documents applies both to the registration of new information on the BO and to cases where information on the BO has already been registered with the Register of Enterprises and it is certified in the application that such information has not changed.