Netherlands restores limited access to its UBO register
The Dutch act restricting access to the UBO registers (Wijzigingswet beperking toegang UBO-registers) was passed by the Senate on 8 July 2025 and largely took effect on 16 July 2025. Public access, suspended since the EU Court of Justice ruling of November 2022, is replaced by access for competent authorities, obliged entities doing customer due diligence, people with a legitimate interest and entities for their own data. A decree setting out who has a legitimate interest followed separately.
The Netherlands stopped all access to its UBO register after the EU Court of Justice held unrestricted public access unlawful on 22 November 2022. The act gives the register a new, restricted access regime.
What changed
- The House of Representatives passed the act unanimously on 18 February 2025, and the Senate on 8 July 2025. Most of it came into force on 16 July 2025.
- Access: competent authorities (now including the EU's AMLA, EPPO, OLAF, Europol and Eurojust), obliged entities for customer due diligence, people who can show a legitimate interest, and legal entities for their own UBO data.
- Legitimate interest: the categories and the checks are set by a governmental decree, which went to consultation and was the subject of a ministerial letter in April 2026.
- The provisions on access to the registers of trusts and similar arrangements commence later.
Who is affected
Dutch companies and their UBOs, and banks, advisers and others who rely on the register for due diligence.