Frequently asked questions about notification of beneficial owners for accounting firms and other representatives

1. The details on the company's board of directors are up to date in the Trade Register. Does the company still have to file a notification of beneficial owners?
2. Who files the notification of beneficial owners?
3. Can an accounting firm file a notification of beneficial owners on behalf of the company?
4. How can companies authorise a representative to file a notification of beneficial owners?
5. Can companies give authorisations in the authorisation service at Suomi.fi?
6. As a representative, how do I file a notification of the company's beneficial owners?
7. Can an accounting firm file the details on the beneficial owners of more than one company at a time?
8. Can I file the notification on a paper form?
9. The details on the beneficial owners of the company have changed after filing the notification. What should I do?
10. Can I file a notification at the same time as I file other changes with the Trade Register?
11. If the parent company is listed on the stock exchange, what should the subsidiary do if it is not listed on the stock exchange?
12. What happens if the details on a beneficial owner you have filed do not match?
13. The limited liability company has no beneficial owners. What should I do?
14. Where can I see if the details on the beneficial owners of the company have been registered?
15. What happens if the beneficial owner details have not been filed by 1 July 2020?

Q: 1. The details on the company's board of directors are up to date in the Trade Register. Does the company still have to file a notification of beneficial owners?

Yes. The company 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: 2. Who files the notification of beneficial owners?

The notification is filed and signed by the person who signs all the company's Trade Register notifications. Read more about how to sign notifications online at ytj.fi.


Q: 3. Can an accounting firm file a notification of beneficial owners on behalf of the company?

Yes, if the company authorises an employee from the accounting firm to file Trade Register notifications on its behalf. You can also fill in the notification without authorisation and then ask, for example, a member of the board of directors to sign the notification in the online service at ytj.fi. Read more: How to file the notification.


Q: 4. How can companies authorise a representative to file a notification of beneficial owners?

Any of the following company representatives entered in the Trade Register can give authorisations:

  • an ordinary member of the board of directors of a limited liability company or cooperative;
  • the managing director; or
  • the partner of a general partnership or the general partner of a limited partnership.

The authorisation is given to a specific person. A company representative gives the authorisation in the online service at ytj.fi (www.ytj.fi). Read more about authorisations at ytj.fi.


Q: 5. Can companies give authorisations in the authorisation service at Suomi.fi?

No. The authorisation is given in the online service at ytj.fi (www.ytj.fi). Read more about authorisations at ytj.fi.


Q: 6. As a representative, how do I file a notification of the company's beneficial owners?

File the notification of beneficial owners in the online service at ytj.fi (www.ytj.fi).
You can sign the notification if you are authorised to file Trade Register notifications on behalf of the company (see question 3). You can also fill in the notification without authorisation and then ask, for example, a member of the board of directors to sign the notification in the online service at ytj.fi. Read more: How to file the notification.


Q: 7. Can an accounting firm file the details on the beneficial owners of more than one company at a time?

No. The details on the beneficial owners of each company must be filed separately in the online service. An employee of the accounting firm can file the details on the beneficial owners of the companies that have authorised the employee to file Trade Register notifications on their behalf (see question 3).


Please note that the company must be registered before you can file their details on beneficial owners. Read more: How to file the notification.


Q: 8. Can I file the notification on a paper form?

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


Q: 9. The details on the beneficial owners of the company have changed after filing the notification. What should I do?

If the details on beneficial owners change, file a new notification of beneficial owners. Read more: How to file the notification.


Q: 10. Can I file a notification at the same time as 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 the notification of beneficial owners must be filed separately. The notification of beneficial owners is free of charge. Read more: How to file the notification.


Q: 11. If the parent company is listed on the stock exchange, what should the subsidiary do if it is not listed on the stock exchange?

Listed companies do not file their beneficial owners. However, subsidiaries that are not listed on the stock exchange must file a notification. This also applies when the subsidiary is wholly owned by the parent company. Read more: Which companies file a notification?


Q: 12. What happens if the details on a beneficial owner you have filed do not match?

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.


Q: 13. The limited liability company has no beneficial owners. What should I do?

Even in this case, the company must file a notification and inform they have no beneficial owners. Read more: How to file the notification.


Q: 14. Where can I see if the details on the beneficial owners of the 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: 15. 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.