At the end of 2022, Law No. 2571-IX entered into force, which amended the legislation on the submission of information on the final beneficial owners (BPOs) of legal entities. Interestingly, there is an opportunity to submit information about the UBO and the ownership structure in electronic form, and about the main changes below:
1. Changes in the terms of submission of information about UBO
The law stipulates that the Ministry of Finance will develop a Methodology for determining the UBO of a legal entity and, accordingly, legal entities will be obliged to disclose or submit corrected information about the beneficiary within six months from the date of approval of the Methodology, but not earlier than three months (90 days) from the date termination of martial law in Ukraine.
2. The requirement for annual reporting on the UBO has been cancelled
The law retained the obligation to maintain up-to-date information on the UBO and the ownership structure of a legal entity, but canceled the requirement to annually submit information on the beneficiary and the ownership structure. Therefore, the message will need to be sent in the following cases:
- within 30 working days from the date of change of information about the UBO or ownership structure;
- during the state registration of changes in a legal entity (for example, a change of manager, location, authorized capital, composition of participants);
- in case of detection of an error – within three working days from the day of detection of the error.
3. Increased responsibility for failure to provide information on the UBO has been established
A fine in the amount of 17 to 340 thousand hryvnias is provided for non-submission or untimely submission of information about the beneficiary or the entry of knowingly inaccurate information. For comparison, previously the maximum amount of the fine was set at the level of 51 thousand hryvnias.