Revised framework for verifying information on UBOs and ownership structure of legal entities

On 13 June 2025, amendments to the procedure for verifying information on ultimate beneficial owners (UBOs) and the ownership structure of legal entities entered into force[1]. These changes aim to enhance transparency upon disclosure of the ownership structure, reduce administrative burden, and improve data quality in the state register.

Under the general procedure established by the Procedure for Verification of Information Provided by a Legal Entity in Explanations and Documents to Confirm Information about UBO and/or Ownership Structure of a Legal Entity, verification is conducted when a state registrar receives a notification of discrepancies between the data in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations (USR) and the information obtained from primary financial monitoring entities.

In such cases, the state registrar sends to the legal entity a letter of demand requesting to provide clarification and supporting documents confirming the validity of the UBO or ownership structure data within 10 business days.

Based on the results of the verification, the state registrar prepares a notification letter, which is sent to the Ministry of Justice of Ukraine.

Key changes effective from 13 June 2025:

• If the letter of demand is returned to the registrar (due to the entity’s absence at its registered address or expiration of the storage period), the registrar must resend the demand one month after the initial attempt.
• According to the mentioned procedure, if the state registrar needs to obtain additional information, the verification period is extended from the date the registrar sends the relevant demand to the legal entity until the date the requested information is received. Under the latest amendments, the legal entity has 10 business days to respond. If no response is received, the state registrar resumes the verification process and upon completion, on the same day sends a notification letter to the Ministry of Justice.
• If the legal entity updates its UBO and ownership structure information in the USR on its own initiative, verification is not initiated, and any ongoing verification is to be terminated. Similarly, the Ministry of Justice should not issue an instruction to remove the UBO or ownership structure data from the USR, and any previously issued instruction should not be executed.
• In addition, information on the UBO or the ownership structure of a legal entity is not removed from the USR in the following specific cases:
  • Sanctions in the form of asset blocking have been applied to the UBO of the legal entity in accordance with the Law of Ukraine “On Sanctions” dated 14 August 2014 No. 1644-VII, or
  • There is information about a court decision prohibiting the performance of a registration action.

[1] The respective amendments were introduced by Order of the Ministry of Justice of Ukraine "On Approval of Amendments to the Procedure for Verification of Information Provided by a Legal Entity in Explanations and Documents to Confirm Information about Ultimate Beneficial Owner and/or Ownership Structure of a Legal Entity" dated 30 April 2025 No. 1173/5.