UBO registration for an Estonian company
(UBO = Ultimate beneficiary owner)
General info and requirements
Since 1st of September 2018, it is required to file information about the UBO(s) in the Commercial registry.
Required info about the UBO includes:
Date of birth
Personal identification code (if there is any)
Country of residence
Nature of the beneficial interest held by the beneficial owner.
UBO data in the registry is not fully public. Info is available for a 1 EUR fee.
Former deadline for submitting the information was October 30, 2018. However, according to the Estonian Ministry of Finance statements, extended deadline for UBO registration is 31 December 2018, thus no sanctions will be applied until that time.
Sanctions (max 3200 EUR) might be applied in case of submitting wrong data or in case the UBO data is not registered.
Nature of beneficiary interest might be one of following:
A holding of more than 50 per cent of the voting rights in the consolidated entity
Right to appoint or remove a majority of the members of the management or the highest supervisory body
Indirect ownership (a company which is under the control of a natural person or multiple companies which are under the control of the same natural person hold more than 25 per cent in a company)
Direct ownership (a natural person holds more than 25 per cent in a company)
Senior managing official i.e. management board member or member of the supervisory board
Remote process and costs for UBO registration
In case the board members of the Estonian company have no Estonian ID (as it is in majority of cases) and they will not visit Estonia in the nearest future, we suggest to do it remotely.
We will draft a declaration form, which has to be signed by the UBO. There is no need for a POA.
Assistance with remote registration of one UBO without a POA
Every additional UBO registration of the same company
Registration of UBO and authorized Contact Person at once
Starting from January 2018, every Estonian company where the directors are not Estonian residents, is required to have an authorized Contact Person who can receive official documents on behalf of the company.
In case your company does not have an authorized Contact Person yet, it is wise to fulfil this requirement along with the UBO registration.
Certified POA for registering UBO and authorized Contact Person
We draft a Power of Attorney (POA), which will give us (KRM Agent) a right to represent the client as the board member of the company in making and submitting entry petitions at the commercial registry.
The same POA can be used for UBO and authorized Contact Person registration both.
The POA must be notarized and also certified with an apostille or legalized, depending on the issuing country. Detailed guidance will be provided during the process.
Assistance with the UBO and authorized Contact Person registration remotely with a POA (incl. one UBO)
Registration of the UBO and authorized Contact Person with a POA includes:
Preparation of the POA
Instructions about signing and certification
Official translation of certified POA and digitalization of POA
Filing changes in the registry
Collecting data about the UBO, based on requirements
This POA allows later to register almost any changes in Commercial register relatively easily (without notarizing any new POAs in the future).
Some additional fees might apply in case the POA is not fully in English/Russian or additional legalization is required (document is signed in a non Hague convention country).