7. Beneficial Owners

A beneficial owner (BO) is a natural person who is the owner of a small‑capital limited liability company or a person who exercises control over a small‑capital 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 small‑capital limited liability company, or who otherwise exercises direct or indirect control over it.


Information on the BO of a small‑capital 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 small‑capital 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 small-capital limited liability company):
      1. on the basis of an authorization agreement;
      2. 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 capital 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).

Information regarding the BO must be provided in the registration application. The BO of a small‑capital limited liability company can always be identified where more than 25 per cent of the shares of the company are directly or indirectly owned by at least one natural person. Unless that person acts on behalf of another natural person, he or she shall be regarded as the BO of the respective company. If a small‑capital limited liability company has several natural persons meeting the above criteria, all such persons shall be regarded as BO in their capacity as shareholders.

If the small‑capital limited liability company has used all available means of identification and has concluded that no natural person can be identified as a BO, and there are no grounds to believe that the legal person has a BO, this shall be confirmed in the application together with the justification for such conclusion.

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.