UBO registration in Denmark: Are you making these common mistakes?

Since 23 May 2017, Danish companies have been legally required to register their UBO, Ultimate Beneficial Owner (reel ejer), to increase transparency and fight financial crime. This obligation was introduced by Act No. 262 of 16 March 2016, aligning Danish law with the EU’s 4th Anti-Money Laundering Directive.

What is a UBO, and why does it matter?

A UBO is the natural person who ultimately owns or controls a company. According to Danish law, someone qualifies as a UBO if they:

  • own more than 25% of shares or voting rights (directly),
  • control ownership through other companies (indirectly), or
  • influence decisions by other means (such as appointing board members or holding veto rights).

If no one meets these conditions, the company must register its management team instead. This ensures someone remains accountable.

Which companies must register UBOs?

In Denmark, most business entities must comply. This includes:

  • Limited liability companies (A/S, ApS, IVS, P/S),
  • Partnerships (I/S, K/S),
  • Cooperatives (AMBA, FMBA, SMBA),
  • European company types (SE, SCE, EEIG),
  • Commercial foundations and Associations with significant assets,
  • Banks, Insurance firms, and Pension providers.

However, some entities are exempt. These include Listed companies, Public institutions, Sole proprietorships, and Voluntary associations. Even so, if an exempt company sits in an ownership chain, the company below it must still assess whether a UBO exists.

How does UBO registration work?

The process happens online, through virk.dk. To register, a company must already appear in the Central Business Register (CVR). After logging in with MitID Erhverv:

  1. Select “Ændre virksomhed” (change company),
  2. Go to the “Ejerforhold” (ownership) section,
  3. Add information under “Reelle ejere” (beneficial owners),
  4. Declare whether ownership is direct, indirect, or based on other control,
  5. Upload ID if the UBO is a foreign national.

Danish residents are verified through the CPR system, so they don’t need to submit extra documents.

What information must be recorded?

Each registration must include the UBO’s:

  • Full name,
  • CPR or foreign ID number,
  • Address and nationality,
  • Date they became a UBO,
  • Shareholding or control percentage,
  • Explanation of influence if based on other means.

Although the company doesn’t upload ownership agreements or shareholder contracts, it must retain them. These documents prove how the UBO was identified.

What about foreign UBOs?

Foreign individuals can be UBOs just like Danish citizens. But since they don’t appear in the national CPR system, companies must provide extra details:

  • Residential address and country,
  • Passport or national ID copy,
  • Date of birth and birth nationality.

These details allow the authority to verify the person through secure databases. The rest of the UBO information remains the same.

Is UBO data public in Denmark?

Only partly. While Denmark’s Central Business Register is publicly accessible, full UBO information isn’t available to everyone. Only individuals with an authorised role in the company and a MitID Erhverv login can see:

  • Full UBO names,
  • Address and country,
  • Ownership percentages or control description.

CPR numbers, passport details, and sensitive identifiers remain private, even for authorised users.

Your UBO record must stay current

UBO registration isn’t a one-time task. Every company must:

  • Review UBO data at least once a year,
  • Update the register immediately when changes occur,
  • Remove individuals who no longer qualify as UBOs.

Ownership transfers, internal restructurings, or changes in control can all trigger new registration duties. Delaying updates can result in penalties or legal exposure.

What happens if you don’t comply?

Failure to register UBOs can trigger real consequences. The Danish Business Authority monitors compliance and takes action when needed. Companies that ignore their duties may face:

  • Financial penalties,
  • Forced dissolution,
  • Investigations or criminal liability in cases of fraud.

Importantly, if the company uses a third party to file the registration, management still holds legal responsibility. Therefore, it’s critical to double-check all submitted data.

Can someone else handle UBO registration?

Yes. Companies may delegate UBO filings to lawyers, accountants, or service providers. However, the company must issue a digital mandate through virk.dk to give them access. If the person handling the filing is based abroad and lacks MitID, a power of attorney may also be required.

Even if someone else files on your behalf, your management remains liable for the accuracy and completeness of the data.

Make UBO compliance one less thing to worry about

UBO compliance is critical, yet often complex and time-consuming. Whether you’re managing updates, restructuring ownership, or preparing for your AGM, Klea makes it easier.

We help companies verify UBO data, document ownership structures, and file updates directly with the Danish Business Authority. Our local partners handle everything securely and on time.

For more insights into processes in other jurisdictions, explore our article, Managing Director Changes in Mexico.

Legal Disclaimer

The information provided on Klea’s website is made available “as is” for informational purposes only. Klea does not provide legal, tax, or financial advice and is not responsible for any actions taken or not taken based on the content found on this website. In no event shall Klea be liable for any loss or damages arising from reliance on the information contained herein.

For specific legal or compliance support tailored to your business needs, please contact Klea directly. Our team provides personalized guidance and expert solutions. Any reliance on general content without direct consultation does not establish any legal responsibility or liability on Klea’s part.

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