Confirmation of Ultimate Beneficial Owners in 2020: Full Guide to Form No. 6

 

The procedure for confirming ultimate beneficial owners (UBO) in 2020 remains a key tool for business transparency and anti-money laundering efforts. Following the full integration of the Ukrainian UBO Register with European monitoring systems, requirements for data accuracy have significantly increased.

In this article, LBA lawyers analyzed the approved application form, the filing procedure, and critical errors that could lead to bank account freezing or heavy fines.

New requirements for UBO disclosure in 2020

Timely confirmation of beneficial owner information is not just a formality, but a guarantee of your business security. In 2020, regulatory bodies are paying special attention to the compliance of data specified in the Unified State Register (USR) with the actual state of affairs.

Neglecting this duty can cause the company to be blacklisted as risky, which automatically halts financial transactions on accounts.

Legal Framework: Ministry of Justice Order and Form No. 6

The main document regulating this issue is the Order of the Ministry of Justice of Ukraine No. 1716/5. It implemented updated application forms in the field of state registration.

“By the Order of the Ministry of Justice of Ukraine No. 1716/5 dated 19.05.2020, updated application forms were approved and Form No. 6 was developed to confirm information about ultimate beneficial owners (UBO), in fulfillment of the duty of all legal entities provided for by Law of Ukraine No. 361.”

Form No. 6 is a specialized tool that allows the state and financial institutions to clearly identify individuals who have a decisive influence on the company’s activities.

Filing Methods: Electronic and Paper Forms

The legislation provides several options for submitting documents. The choice depends on the technical readiness of the registers and the needs of the legal entity itself.

Main ways of submitting applications include:

• Electronic form: Carried out using software tools after their full implementation. The application is formed in a free format suitable for content perception.
• Paper form: Used for choosing a simplified taxation system, VAT registration, or inclusion in the Register of Non-profit Institutions.
• Simplified format: The possibility of filing without entering the manager’s phone number or email address into the USR (until the technical update of the register is completed).

Registration Nuances and ASC (TSNAP) Operations

Despite digitalization, in many regions, the work of Administrative Service Centers (ASC/TSNAP) may have limitations. Using registration services or making changes to existing data through ASCs can sometimes be difficult due to their unstable work pace.

It is important to understand that legal liability for data accuracy and timely updates rests solely with the company’s management.

LBA Lawyers’ Assistance in UBO Confirmation

Law Business Association law firm provides full support for the ownership structure disclosure procedure. We help avoid bureaucratic traps and guarantee the correct completion of Form No. 6.

We provide all types of assistance in the field of state registration of legal entities, individual entrepreneurs (FOP), and public formations in the shortest possible time.

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About the Author

Denys Fedorkin — Managing Partner of Law Business Association (LBA). Has over 17 years of experience in business protection, tax law, and corporate security. Specializes in comprehensive legal support and anti-raider measures.

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