Netherlands Beneficial Ownership Register (KvK): UBO Data, Access Restrictions & the 2026 API
Last updated: 27 October 2026 · Reviewed against KVK’s UBO access, extract and filing pages (October 2026), the Handelsregisterwet 2007, Staatsblad 2025, 190, Staatscourant 2025, 44689, the draft legitimate-interest decree of 2 April 2026 and the CJEU judgment in C-37/20
1. The Netherlands UBO Register: The State of Play in 2026
The Netherlands built one of the EU’s most complete UBO registers — every unlisted BV, NV, foundation, association and partnership had to file by March 2022 — and then spent more than three years unable to show it to the banks that are obliged to check it. For compliance teams, KYB platforms, and due diligence analysts working with Dutch counterparties, the UBO register is a critical data source — and one of the most operationally complex to reach in the EU.
The Dutch UBO register is maintained by the Kamer van Koophandel (KvK) — the Chamber of Commerce — as part of the Handelsregister (Trade Register), under the Handelsregisterwet 2007 (Trade Register Act). It implements the EU’s AMLD4 and AMLD5, and it serves the obligations of the Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft), the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act. Most entities were required to file by March 27, 2022.
Three events reshaped access after 2022: the CJEU ruling of 22 November 2022 that closed public access, the Amendment Act in force since 16 July 2025 that reopened the register to defined institutions, and KVK’s sector-by-sector return of online extracts and a UBO API from the second quarter of 2026. The catch is the event that has not happened: the legitimate-interest route EU law required by 10 July 2026 is still a draft decree.
- Register access: closed to the public. Institutions see one of three access levels: banks and other financial institutions (UBOB2) and Wwft professionals such as accountants, lawyers and trust offices (UBOB1) see name, month and year of birth, country of residence, nationality and the size of the interest; only the FIU and competent authorities (UBOB3) see full date of birth, address and BSN (KVK, edited 26 October 2026).
- Latest change: since the second quarter of 2026, authorised institutions can again order UBO extracts online with eHerkenning or through a UBO API. KVK admits them sector by sector, and only “objectively identifiable” organisations — licensed by, or registered with, a supervisor or mandatory professional body — qualify.
- Legitimate interest: the EU deadline of 10 July 2026 has passed. The Finance Minister sent a draft decree to parliament on 2 April 2026; KVK still describes the proposals as being prepared.
- Enforcement: since 1 January 2026 the Ministry of Finance’s DFEI imposes administrative fines of up to €27,500 for missing or wrong UBO filings, starting at 10% for a first breach (Staatscourant 2025, 44689).
- What a verifier gets today: if you are not an authorised Dutch institution, nothing direct. The entity itself can order a sealed UBO extract in My KVK for €3.10 and hand it to you (KVK UBO extract). The Netherlands is on neither FATF list as of the June 2026 plenary.
This article is part of Zavia.ai's Global Ownership Data Index, covering UBO and corporate data availability across 173 countries. The Netherlands is covered in the EU & EEA section, scored as Restricted for UBO access.
2. What Is a UBO Under Dutch Law?
The Wwft defines a UBO as the natural person who ultimately owns or controls a Dutch legal entity. The definition follows the EU standard closely but includes specific Dutch interpretations that matter for cross-border compliance work.
The 25% threshold
A natural person qualifies as a UBO if they directly or indirectly hold more than 25% of shares, voting rights, or ownership interest in the entity. Indirect ownership is calculated through the entire holding chain: a person holding 60% of a company that itself holds 50% of a Dutch BV qualifies, because their indirect stake (30%) exceeds the threshold.
Control by other means
If no individual meets the 25% threshold through ownership or voting rights, the "control by other means" test applies. This covers individuals who have the authority to appoint or dismiss the majority of the organisation's management, or who exercise equivalent dominant influence over the entity's decisions.
The "pseudo-UBO" rule
When exhaustive analysis cannot identify any natural person through either ownership or control tests, Dutch law requires the designation of a pseudo-UBO. This consists of all natural persons who collectively comprise the statutory senior management — typically the board of directors or managing directors (hoger leidinggevend personeel). Unlike some EU jurisdictions, the Netherlands does not use the term "last resort UBO" — the pseudo-UBO designation is applied universally where no individual UBO can be identified.
Under the EU Anti-Money Laundering Regulation (AMLR) applying from July 10, 2027, the threshold shifts from "more than 25%" to "25% or more." Any person holding exactly 25% will qualify as a UBO. Companies with shareholders at exactly 25% will need to revise their UBO registrations. Our guide to AMLR, AMLD6 and AMLA covers the EU side.
Which entities must register?
| Entity Type | Must Register? | Notes |
|---|---|---|
| Private limited companies (BV) | ✓ Yes | Unlisted only; listed BVs and their 100% subsidiaries are exempt |
| Public limited companies (NV) | ✓ Yes | Unlisted only |
| Foundations (Stichtingen) | ✓ Yes | Including foundations used as holding entities |
| Associations with full legal capacity | ✓ Yes | Including those with limited capacity but conducting business |
| General partnerships (VOF), limited partnerships (CV) | ✓ Yes | All commercial partnerships except silent partnerships without business activity |
| Cooperatives and mutual insurance societies | ✓ Yes | — |
| European economic interest groupings (EEIG) | ✓ Yes | Registered office in Netherlands per their statutes |
| Trusts and similar legal arrangements | ✓ Yes | Separate UBO Register for Trusts (in force from November 2022) |
| Religious denominations | ● Pending | Required but implementation date not yet confirmed by KvK |
| Listed companies & their 100% subsidiaries | ✗ Exempt | Subject to separate public disclosure requirements |
| Sole proprietorships (eenmanszaken) | ✗ Exempt | — |
| Foreign entities with only a Dutch branch | ✗ Exempt | Must register UBOs in their country of origin |
3. What UBO Data Is Actually Available in the Dutch Register
The KvK register holds more than any institution outside government can see. Access is set by three levels in the Business Register Decree 2008 (UBOB1, UBOB2 and UBOB3), and the split matters: a bank and a law firm see the same five fields, but only a bank still sees them when the UBO has had their details shielded.
| Data Field | Held in Register? | Accessible? | Notes |
|---|---|---|---|
| Full legal name | ✓ Yes | ● UBOB1–3 | Hidden from UBOB1 if the UBO’s details are shielded |
| Month and year of birth | ✓ Yes | ● UBOB1–3 | Full date held; institutions see month and year |
| Country of residence | ✓ Yes | ● UBOB1–3 | Hidden from UBOB1 if shielded |
| Nationality | ✓ Yes | ● UBOB1–3 | Hidden from UBOB1 if shielded |
| Nature and size of interest (%) | ✓ Yes | ● UBOB1–3 | Banded ranges (25–50%, 50–75%, 75–100%); the only field UBOB1 sees for a shielded UBO |
| Full date, place and country of birth | ✓ Yes | ● UBOB3 only | FIU and competent authorities |
| Home address | ✓ Yes | ● UBOB3 only | Not disclosed to Wwft institutions |
| Citizen service number (BSN) or foreign TIN | ✓ Yes | ● UBOB3 only | Not disclosed to Wwft institutions |
| Ownership chain / corporate structure | ✗ No | ✗ No | Register shows the declared UBO, not the holding path |
| Historical ownership changes | ✗ No | ✗ No | Institutions see the current registration |
| PEP / sanctions flags | ✗ No | ✗ No | Must be cross-referenced from external sources |
The Amendment Act in force since 16 July 2025 restored access for Wwft and sanctions-law institutions in law. KVK restored it in practice from the second quarter of 2026: online ordering with eHerkenning and a UBO API. It cannot authorise every organisation at once, so it invites sectors in turn through their sector organisations. Until a sector’s turn comes, its members still depend on clients ordering their own extract and handing it over — and some clients cannot, for example where a complicated holding structure blocks the order (KVK).
4. Who Can Access the Dutch UBO Register?
The Netherlands has gone through a turbulent access history since 2022. The current situation — access defined in law, partly switched back on, and still closed to anyone outside the authorised sectors — is unusual in the EU.
Current access categories (as of October 2026)
| Category | Legal Access | Practical Status | Method |
|---|---|---|---|
| FIU-NL and competent authorities (police, tax, prosecution, DNB, AFM and others) | UBOB3 — all fields | Operational | API or KVK website |
| Banks, investment firms, payment and e-money institutions, life insurers (Wft Art. 1:1) | UBOB2 — five fields, even if shielded | ● Sector-by-sector authorisation | eHerkenning or UBO API; client extracts meanwhile |
| Accountants, lawyers, trust offices (Wwft Art. 1a); insurers and pension funds (Sanctions Act) | UBOB1 — five fields, interest only if shielded | ● Sector-by-sector authorisation | eHerkenning or UBO API; client extracts meanwhile |
| Civil-law notaries, bailiffs, Bibob bodies and other public-task bodies (Art. 51aa HRB) | UBOB3 | ● On application | Apply to KVK by email |
| Persons with legitimate interest | Draft decree of 2 April 2026 | Not available | EU deadline of 10 July 2026 missed |
| Registered UBO and the entity itself (own data) | Own data only | Operational | My KVK with DigiD or European eID; extract €3.10 |
| General public | None | Closed since Nov 2022 | No access route |
AMLD6 required member states to open the register to people and organisations with a legitimate interest by 10 July 2026. The Dutch draft decree, sent to parliament on 2 April 2026, sets a closed list — journalists holding an NVJ press card, civil-society organisations working against money laundering, scientific institutions, and parties about to transact with the entity — with KVK deciding applications and issuing a certificate valid for three years. KVK itself warned that full implementation by the deadline was not feasible. As of October 2026 there is still no application route.
5. Is Access Free? Cost and Availability Breakdown
| Access Method | Cost | What You Get |
|---|---|---|
| KvK Handelsregister (basic company data) | Free (basic) / paid extracts | Company name, KvK number, RSIN, registration date, legal form, address, directors — no UBO data |
| KvK certified UBO extract (own company) | €3.10 per extract | Digitally sealed, in Dutch, downloadable for 24 hours; orderable only by a person authorised to sign for the entity or to view its UBO data (KVK) |
| KvK UBO API and eHerkenning ordering | Paid; for authorised institutions only | Programmatic UBO extracts for Wwft and sanctions-law institutions — live since Q2 2026, sector by sector |
| KvK Business Open Data Set (bulk) | Free | Location, registration date, activity, legal form, dissolution date — fully anonymised; no company names or KvK numbers |
| KvK Zoeken API (company search) | Fixed monthly + per-query | Entity search, basic firmographic data — no UBO or shareholder data |
| Legitimate interest access | — | Not available; draft decree of 2 April 2026 not in force |
For anyone outside the authorised sectors, the certified extract model — where a company orders its own extract and hands it to its bank, notary or counterparty — is still the only route. It is a stopgap, not a scalable compliance workflow, and it depends on the counterparty’s willingness to cooperate.
6. Penalties for Non-Compliance
Since 1 January 2026, a missing, wrong or incomplete UBO filing by a company or other legal entity is enforced by administrative fine. The Minister of Finance has mandated that power under Article 47b of the Handelsregisterwet 2007 to the Dienst Financieel-Economische Integriteit (DFEI). The statutory maximum is a fourth-category fine, currently €27,500. Under the policy rule published in Staatscourant 2025, 44689, the starting point is 10% of that maximum, doubled for a repeat breach within five years and rising in steps to the full amount. A parallel policy rule for trusts has applied since 1 June 2026. Criminal prosecution of the same breach remains possible.
An institution that obtains a UBO extract — from KVK or through its client — carries the feedback obligation (terugmeldplicht): if its own due diligence shows different UBO data, it must report the discrepancy to KVK. With access returning sector by sector, many institutions still work from client-supplied extracts, which makes the discrepancy check the one control they can run on every file.
The 7-day update window applies without exceptions: KVK requires a UBO report within 7 days of a change becoming official, and within 7 days when a person stops being a UBO (KVK UBO report). Any change to a UBO's information — ownership percentage, address, new UBO arriving, existing UBO departing — is covered.
7. Existing Legislation
| Legislation | Year | Key Provision |
|---|---|---|
| EU 4th AML Directive (AMLD4) | 2015 | Required member states to establish UBO registers for companies |
| EU 5th AML Directive (AMLD5) | 2018 | Required public access to UBO registers; Netherlands implemented in 2020 |
| Dutch UBO Register launch (Wwft implementation) | Sept 2020 | Register goes live; part of UBO data publicly accessible |
| UBO Register Trusts Implementation Act | Nov 2022 | Separate register for trusts and similar legal arrangements; trustees must register UBOs |
| CJEU Ruling (Cases C-37/20 & C-601/20) | Nov 2022 | Struck down general public access; KvK stops all disclosure from the register |
| Amendment Act on Restricting Access to UBO Registers (Stb. 2025, 189) | Jul 2025 | In force 16 July 2025; restores access for Wwft and sanctions-law institutions and competent authorities |
| DFEI administrative-fine policy rule (Stcrt. 2025, 44689) | Jan 2026 | Fines up to €27,500 for UBO filing breaches, starting at 10% for a first breach |
| Draft legitimate-interest decree | Apr 2026 | Implements Articles 12–14 of AMLD6; sent to parliament 2 April 2026, not yet in force |
| EU AML Package (AMLD6 + AMLR) | 2024 adopted | Legitimate-interest access due by 10 July 2026; AMLR applies from 10 July 2027 |
8. What Changed in 2026, and What Comes Next
1. KvK UBO API and online ordering (live since Q2 2026)
This is the change that matters most for Dutch institutions. Since the second quarter of 2026, KVK again lets authorised organisations order UBO extracts online with eHerkenning, and it offers a UBO API that can be built into KYC and CDD systems. The catch is pace: KVK cannot authorise every organisation at once, so it invites sectors in turn through their sector organisations. Until a sector is called, its members keep working from client-supplied extracts.
KVK may only grant access to “objectively identifiable” organisations: those holding a licence from, or registered with, a supervising authority or mandatory professional body. A foreign bank or KYB platform with no Dutch licence does not qualify, whatever login it holds. KVK says similar organisations from other member states will reach the Dutch register over the coming years through BORIS, the EU interconnection on the European e-Justice Portal.
2. Legitimate-interest access (deadline missed)
The draft decree sent to parliament on 2 April 2026 implements Articles 12, 13 and 14 of AMLD6. It sets a closed list of categories: journalists (NVJ press-card holders and members of the Foreign Press Association), journalistic organisations, non-profit civil-society organisations whose statutes target money laundering, scientific institutions, and persons likely to enter a transaction with the entity. Journalists and civil-society organisations get categorical access; others are assessed case by case. KVK decides within twelve working days and issues a certificate valid for three years. None of it is in force.
3. Historical ownership data
Institutions see the current registration. There is no view of who the UBO was before a restructuring, which leaves retrospective due diligence dependent on the entity’s own records and on corporate filings elsewhere.
4. Threshold change: "more than 25%" to "25% or more" (July 2027)
The AMLR shifts the ownership threshold slightly. Any person holding exactly 25% of shares, voting rights, or ownership interest will qualify as a UBO from July 10, 2027. Companies with shareholders at exactly 25% will need to revise their UBO registrations when the new rules take effect.
For Dutch-supervised institutions, 2026 closed the worst of the gap: an API and online ordering are back. For everyone else — foreign institutions, journalists, counterparties — the register is still shut until the legitimate-interest decree takes effect and BORIS connects the EU registers. Plan for an API-driven workflow at home and a client-extract workflow abroad.
9. The Real Challenges of Accessing Dutch UBO Data
9.1 Access returns slowly, sector by sector
Banks, notaries, insurers, accountants, and lawyers are all legally required to verify their clients' UBO data. Since the second quarter of 2026 some of them can do it through KVK directly again; the rest wait for their sector’s turn and depend on clients requesting and submitting their own certified extracts. That creates friction, delays, and a material compliance risk, particularly for complex holding structures or uncooperative clients.
9.2 No legitimate interest access route (deadline missed)
Unlike France, which runs a functioning (if slow) legitimate interest application process, the Netherlands has only a draft decree. As of October 2026, there is no application process. Journalists, researchers, civil society, and businesses wanting to verify counterparties have no formal route to Dutch UBO data.
9.3 Authorisation is limited to Dutch-supervised institutions
KVK’s UBO API and online ordering are open only to organisations licensed by or registered with a Dutch supervisor or mandatory professional body. Foreign compliance teams, overseas Wwft-equivalent institutions, and non-Dutch KYB platforms cannot use them. Until BORIS connects the registers, the practical route is the counterparty’s own €3.10 extract.
9.4 No ownership chain resolution
The Dutch UBO register records the declared UBO — the natural person at the end of the ownership chain. It does not map the intermediate corporate structure. A Dutch BV owned by a Luxembourg SARL owned by a Cayman Islands company: the register tells you who the declared UBO is; it does not show how control flows from the Cayman entity through Luxembourg to the Netherlands. Resolving the full chain requires combining Dutch data with corporate records from each intermediate jurisdiction.
9.5 KvK shareholder data is not structured
The Handelsregister does not provide structured, machine-readable shareholder data. Company filings only list the main shareholder, and the relationship between shareholding data and UBO data is not automatically resolved. For cross-border UBO verification workflows, this means Dutch KYB typically requires combining registry data with UBO register data from two separate sources — neither of which is easily accessible at scale.
9.6 No historical data
The Dutch UBO register gives institutions the current registration only. There is no way to determine from it who was the UBO six months ago, what ownership percentage they held before a restructuring, or when a particular individual was added to or removed from the register. This gap is significant for retrospective due diligence, litigation support, and financial crime investigations.
9.7 Self-declared data, newly enforced
The register reflects what was filed. KVK checks the filing and the person, but the ownership analysis behind it is the entity’s own. Administrative fines only moved to the DFEI in January 2026, and the feedback obligation on institutions is the main way discrepancies reach KVK. A meaningful portion of the register can therefore reflect what was filed rather than the current ownership reality.
10. How Zavia.ai Resolves Dutch UBO Access
Zavia.ai connects to KvK’s Business Register and the Netherlands' official company data infrastructure — providing structured, API-accessible company, director and ownership data for Dutch entities, resolved across borders, without building and maintaining a separate KvK integration. It does not replace the UBO register: a Dutch institution still checks the register, and a foreign one still asks for the extract. What it adds is the chain around the declared UBO.
🇳🇱 Netherlands UBO Data via the Zavia.ai API
One API endpoint. Real-time access to Dutch company registry data, directors and shareholders — sourced from KvK and the Handelsregister — with ownership resolved across borders. No eHerkenning account required.
- Real-time company and ownership queries for any Dutch KvK number
- Cross-border ownership chain resolution
- Corporate linkage — subsidiaries, parents, group structure
- Bulk data delivery — licensed file exports at scale
- Sanctions overlay and KYB verification workflow
- Historical company data and director history
- 173-country coverage — one integration, global reach
- Full reseller and redistribution rights available
Working around the authorisation barrier
KVK’s UBO API is open only to Dutch-supervised institutions. For non-Dutch compliance teams, overseas financial institutions, and global KYB platforms, the workable sequence is to map the ownership chain from registry data first, then ask the counterparty for its own KVK UBO extract and check the two against each other. Zavia.ai supports the first step across 173 countries through a single international API endpoint, with no Dutch entity registration or eHerkenning credentials required.
Cross-border ownership chain resolution
The Dutch UBO register tells you who the declared UBO is. It does not show you how they control the entity. For a Dutch BV owned through a Luxembourg SARL and a Cayman Islands holding company, Zavia.ai resolves the full ownership chain across all three jurisdictions — connecting Dutch KvK data with 173 countries of government-sourced corporate and ownership data in a single structured API response.
Bulk data delivery for compliance platforms
For compliance platforms, financial institutions, and data products that need Dutch company and ownership data at scale, Zavia.ai offers structured bulk data file delivery. Licensed extracts updated on a defined cadence, delivered in your preferred format. Full reseller rights available for redistribution use cases. Browse the Netherlands company directory to see the coverage.
A Dutch BV whose declared UBO holds exactly 26% through two holding entities in different jurisdictions may appear compliant in the KvK register. Zavia.ai traces the full chain above and below the Dutch entity — surfacing indirect controllers, circular ownership structures, and cross-border linkages that the KvK register alone cannot show.
