Disclosure of company ownership structure becomes mandatory in Ukraine

Editorial Team Compliance, Law

A three-month campaign to collect disclosures from legal entities of their ownership structure and ultimate beneficial owners began July 11, 2021. The deadline was later extended to July 11, 2022.

This requirement was introduced by the new Law of Ukraine “On prevention and combating money laundering and terrorism financing and Financing Weapons of Mass Destruction Proliferation” № 361-IX dated 06.12.2019, later explained by an Order of the Ministry of Finance of Ukraine № 163 dated 19.03.2021.

Under the law, by July 11, 2022, all companies are required to submit documents to the Unified State Register of Legal Entities, Private Entrepreneurs and Public Formations (Companies Register) providing details of their ultimate beneficial owners. Here is the list of documents that must be submitted:

  1. An application for state registration of a legal entity (form 2);
  2. Ownership structure outlined in a free form with a schematic representation indicating all persons who directly or indirectly own the company;
  3. An extract, excerpt, or other documents from a commercial, banking, or court register, confirming registration of a non-resident legal entity in the country of its location (for non-resident legal entities shareholders);
  4.  Certified copies of the passports of ultimate beneficial owner(s). 

Information on the ultimate beneficial owners must be disclosed in two stages:

  1. Initial submission of information;
  2. An annual update, within 14 calendar days of the date of state registration of a legal entity.

The Law also requires legal entities to regularly update information on the ultimate beneficial owners and ownership structure and notify the state registrar of any changes within 30 working days, by submitting documents confirming these changes.


Violating the deadline will result in a fine of UAH 17 000 to UAH 51 000, against the Director of the legal entity or a person authorized to act on behalf of the legal entity (the Executive Body).

Based on the above, in case you have a company in Ukraine, we highly advise you to comply with the above requirements and disclose ownership structure as required by law.

Should you have any further questions or require assistance, please do not hesitate to contact us.