Since 3 July 2026, obliged entities may, in the context of their anti-money laundering and counter-terrorist financing (AML/CFT) obligations, also access the supporting documents underlying the information recorded in the UBO Register. This possibility follows from the Royal Decree of 12 June 2026.
Until now, obliged entities could consult the UBO information recorded in the Register but did not have access to the corresponding supporting documents. As a result, documents that were already available in the UBO Register sometimes had to be requested again from the client.
This new measure is consistent with the administrative simplification advocated by Becobra: information and documents already available through official registers should, where possible, be reusable rather than repeatedly requested from clients.
Access to the supporting documents also facilitates the verification of information contained in the UBO Register. Obliged entities are required to electronically report to the General Administration of the Treasury any discrepancy they identify between the beneficial ownership information recorded in the UBO Register and the information available to them. Access to the underlying supporting documents makes it easier to compare the registered information with the information collected as part of customer due diligence (CDD) and to identify any discrepancies.
What does this mean for you?
The new access does not alter the intermediary’s own AML/CFT and CDD responsibilities. The UBO Register is a source of information but does not relieve the intermediary of its obligations to identify and verify beneficial owners. Where a discrepancy is identified as a result of this comparison, it must be reported to the General Administration of the Treasury.
Information and documents contained in the UBO Register may furthermore only be accessed and used for the purposes for which access is legally permitted and must be processed in accordance with applicable data protection requirements.
