Beneficial ownership confirmation in Ukraine requires a legal entity to keep information on its ultimate beneficial owners and ownership structure properly documented and reflected in the state register. Clear ownership records make corporate filings easier to manage and reduce the risk of administrative problems when company information is reviewed.

Ministry of Finance Order No. 163 approved requirements for the form and content of company ownership structures. Legal entities use this framework to document and update information on ultimate beneficial owners.

An ultimate beneficial owner is an individual who exercises influence over the management of a legal entity and holds a 25% or greater interest in the company's authorised capital.

The campaign for updating or confirming information about owners was scheduled to begin on 11 July 2021 and continue through 10 October 2021 inclusive. During this period, the documents prescribed by law were to be submitted to the state registrar and beneficial ownership information in the Unified State Register was to be updated.

In addition to the application and passport details of the beneficial owners, the company's ownership structure must be submitted in graphical form showing information about the owners of the legal entity.

Sample ownership structures were published by the Ministry of Finance of Ukraine on its website.

The ownership structure should indicate:

• the size of each owner's participation;

• persons who, irrespective of formal ownership, are able to exercise significant influence over the management or activities of the legal entity;

• a description of the manner and nature of the ultimate beneficial owner's decisive influence over the activities of the legal entity.

The Code of Ukraine on Administrative Offences provides for a fine of UAH (Ukrainian hryvnia) 17,000 to UAH 51,000 for failure to comply with ultimate beneficial ownership requirements. The fine is imposed on the head of the legal entity.

This procedure must also be completed annually. The legislation provides only 14 calendar days from the anniversary date of the company's registration.

We can also remind you the following year when the documents need to be submitted in order to avoid a fine.

To provide the service, we require the following information:

• company identification code;

• scanned copy of the ultimate beneficial owners' passports;

• photograph or copy of the residence registration certificate;

• photograph or copy of the tax identification number.

Ownership compliance strategy should keep beneficial-owner data, the ownership chart and supporting identification documents ready for the required filing cycle. Consistent records reduce corrective filings and make future corporate changes easier to complete.