Ukraine: regulated firms must report beneficial ownership discrepancies, and the register flags them
From 1 September 2024, Ukrainian financial monitoring entities such as banks, auditors, accountants and notaries must report to the Ministry of Justice any mismatch between a company's beneficial ownership and ownership structure data in the Unified State Register and what they find in due diligence. The registrar then marks the entry as potentially unreliable and asks the company to explain. Fines for missing updates are suspended during martial law.
The procedure is set by Ministry of Justice Order No. 2542/5 of 12 July 2023.
What changed
- Reporting: primary financial monitoring entities, including banks and other financial service providers, payment system operators, auditors, accountants, tax and legal advisers and notaries, report discrepancies to the Ministry of Justice.
- Process: the Ministry passes the notice to the state registrar within 10 business days without revealing who reported it. Within three business days the registrar adds a note of potential unreliability to the register and asks the company for explanations.
- Outcome: if the data is shown to be wrong, the note stays; if it cannot be verified, the information can be removed from the register.
- Ongoing duty: companies must keep beneficial ownership and ownership structure information current and report changes to the registrar within 30 business days.
- Penalties: fines of roughly USD 400 to USD 8,000 can apply, but liability for failing to update this information is suspended during martial law and for three months after it ends.
Later developments
Changes to the verification procedure took effect on 13 June 2025, giving companies 10 business days to answer a registrar's request. A Government bill (No. 13233) approved in April 2025 would further amend the beneficial ownership rules.
What to do
Check that each Ukrainian company's register entry matches what it gives its banks and advisers, and clear any unreliability mark promptly.