Frequently asked questions about notification of beneficial owners for companies

1. Who is a beneficial owner?
2. Must all companies file a notification of their beneficial owners?
3. The details on our company's board of directors are up to date in the Trade Register. Do we still have to file a notification of beneficial owners?
4. I am a private trader. Do I need to file a notification?
5. Why do I need to file a notification on beneficial owners?
6. Are there similar obligations in other countries?
7. How do I file the notification?
8. What do I need to file the notification?
9. Can I fill in the notification on a paper form and sent it by post?
10. What details do I need to fill in the notification?
11. Does the notification cost anything?
12. When do I need to file the notification?
13. What is indirect ownership or exercise of voting rights?
14. If I own exactly 25 percent of the company, am I a beneficial owner?
15. Our limited liability company has no beneficial owners who own more than 25 percent of the company. What should we do?
16. Who files the notification?
17. Can my accounting firm file my company's details on beneficial owners?
18. Can my company's holder of procuration file the details on beneficial owners?
19. Can I file the beneficial owners while I file other changes with the Trade Register?
20. In our company, the managing director and the members of the board of directors do not have a Finnish personal identity code. How do we file the notification?
21. The details on the beneficial owners of my company have changed after filing the notification. What should I do?
22. Who can access the details on beneficial owners?
23. Where can I see if the details on the beneficial owners of my company have been registered?
24. What happens if the beneficial owner details have not been filed by 1 July 2020?

Q: 1. Who is a beneficial owner?

A person who meets any of the following requirements is considered as a beneficial owner:

  • The person owns more than 25 percent of the company shares directly or indirectly through another company.
  • The person holds over 25 percent of the voting rights in the company directly or indirectly through another company.
  • The person exercises actual control over the company on other grounds.
A beneficial owner is always a person. For example, the estate of a deceased person, a company, an organisation, a county or any other public entity cannot be filed as a beneficial owner. Read more: Who is a beneficial owner?

Q: 2. Must all companies file a notification of their beneficial owners?

The obligation to file the notification applies to all limited liability companies and cooperatives. General partnerships and limited partnerships file a notification only if the beneficial owner is a person other than a partner. Listed companies, mutual real estate companies and private traders do not file a notification. Read more: Which companies file a notification?


Q: 3. The details on our company's board of directors are up to date in the Trade Register. Do we still have to file a notification of beneficial owners?

Yes. You must file a separate notification of beneficial owners with the Trade Register because the beneficial owners are not necessarily persons responsible for the company, such as board members. The notification must also be filed even if the company has no beneficial owners. Read more: Who is a beneficial owner?


Q: 4. I am a private trader. Do I need to file a notification?

No. The following companies and organisations do not file a notification on beneficial owners: private traders, listed companies, housing companies, mutual real estate limited companies, associations, foundations, and religious communities. Read more: Which companies file a notification?


Q: 5. Why do I need to file a notification on beneficial owners?

The obligation to file the details is based on the Act on Money Laundering and EU directives. They require, among other things, that accounting firms, banks and law firms know their customers and check the beneficial owner details of the company. Filing and updating beneficial owner details make operations easier for both the company and its representative.


Q: 6. Are there similar obligations in other countries?

Yes, the obligation to file the details on beneficial owners applies to all EU member states. For example, the companies in Sweden and Estonia have already had to file their details.


Q: 7. How do I file the notification?

File the notification in our online service at ytj.fi. The notification of beneficial owners is free of charge. Read more: How do I file a notification?


Q: 8. What do I need to file the notification?

You need to have a Finnish personal identity code and either personal internet banking codes, a mobile certificate, or an electronic identity card (HST card). Read more: How do I file a notification?


Q: 9. Can I fill in the notification on a paper form and sent it by post?

You can file the notification using a paper form only in exceptional cases. Read more: How to file the notification using a paper form (in exceptional cases only)


Q: 10. What details do I need to fill in the notification?

The following details are entered in the register:

  • name;
  • Finnish personal identity code or date of birth;
  • nationality;
  • country of residence;
  • municipality of residence; and
  • the grounds and scope of control or ownership.


The PRH provides details on beneficial owners from the Trade Register to those whose purpose of use of the details is in accordance with the Act on Money Laundering. Read more about the details on beneficial owners.


Q: 11. Does the notification cost anything?

No, filing details on beneficial owners is free of charge.


Q: 12. When do I need to file the notification?

You must file a notification without delay in the following situations:

  • The company has not filed its beneficial owner details with the Finnish Trade Register between 1 July 2019 and 1 July 2020.
  • The beneficial owner details have changed.
  • A new company has been registered.
  • You are no longer a beneficial owner of the company.

Please note: The company must file the notification even if the company has no beneficial owners defined in the Act on Money Laundering or the company does not know them. Read more: Which companies file a notification?


Q: 13. What is indirect ownership or exercise of voting rights?

Indirect ownership or exercise of voting rights refer to a situation where control is exercised through another company. A person may be the indirect owner of company A, for example, if company B owns 30 percent of company A and the person owns 55 percent of company B. In this case, the person is the indirect owner of company A. Read more: Who is a beneficial owner?


Q: 14. If I own exactly 25 percent of the company, am I a beneficial owner?

You are not a beneficial owner, because you do not own more than 25 percent of the company. The beneficial owners defined in the Act on Money Laundering are those who own at least 25.01 percent of the company. Read more: Who is a beneficial owner?


Q: 15. Our limited liability company has no beneficial owners who own more than 25 percent of the company. What should we do?

Check again if there is a person in your company who exercises actual control over the company on other grounds (for example a partnership agreement). If not, your company has no beneficial owners defined in the Act on Money Laundering. Even in this case, your company must file a notification of beneficial owners. Read more: How to file the notification.


Q: 16. Who files the notification?

The person who signs the company's other Trade Register notifications, such as a member of the board of directors, managing director, or a general partner files the notification. You can also authorise for example an employee from your accounting firm to file the notification. Read more: How to file the notification.


Q: 17. Can my accounting firm file my company's details on beneficial owners?

A representative authorised to file notifications with the Trade Register, such as an employee from your accounting firm, can file the notification on behalf of your company. Your company can give authorisations in the online service at ytj.fi (www.ytj.fi). Please note: you cannot give authorisations in the authorisation service at Suomi.fi. Read more about authorisations on the ytj.fi website.


Q: 18. Can my company's holder of procuration file the details on beneficial owners?

No, because procuration rights are not enough to sign the notification of beneficial owners or other Trade Register notifications. Read more: How to file the notification.


Q: 19. Can I file the beneficial owners while I file other changes with the Trade Register?

No. You can file the details on beneficial owners in the same online service at ytj.fi, but you must file the notification of beneficial owners separately. The notification of beneficial owners is free of charge. Read more: How to file the notification.


Q: 20. In our company, the managing director and the members of the board of directors do not have a Finnish personal identity code. How do we file the notification?

If none of the persons responsible for the company has a Finnish personal identity code or an opportunity to obtain one, your company files the notification exceptionally by using a paper form. Read more: How to file the notification.


Q: 21. The details on the beneficial owners of my company have changed after filing the notification. What should I do?

After filing the notification, you must keep the details up to date. If the details change, file a new notification of beneficial owners. Read more: How to file the notification.


Q: 22. Who can access the details on beneficial owners?

The PRH provides details on beneficial owners from the Trade Register to those whose purpose of use of the details is in accordance with the Act on Money Laundering. Read more: Information services and details on beneficial owners.


Q: 23. Where can I see if the details on the beneficial owners of my company have been registered?

Use the search on the start page of our Virre Information Service to check if there is a notification of beneficial owners registered for the company or organisation. The registration of a notification of beneficial owners is indicated in the basic details of the company or organisation. Go to Virre Information Service.


Q: 24. What happens if the beneficial owner details have not been filed by 1 July 2020?

Information on whether the beneficial owner details have been filed is indicated on the company’s Trade Register extract.
In practice, it may become difficult for the company to carry out its operations if it does not file a notification of beneficial owners. For example, banks, accounting firms and law firms are obligated to identify their customers and check the beneficial owner details. They can also report to the PRH about any deficiencies or inconsistencies in the company’s beneficial owner details.
Under the Finnish Business Information Act, a fine can be imposed if the notification obligation is neglected. Filing incorrect information on purpose is a registration offence defined in the Criminal Code. Incomplete details or details that have changed must always be filed with the PRH without delay. Read more: How to file the notification.