Ukraine | Form and content of ownership structure for legal entities approved


On 11 July 2021, the Ministry of Finance Order No. 163 “On Approval of the Regulation on the Form and Content of the Ownership Structure” of 11 June, 2021, will enter into force.

In 2019, Ukraine comprehensively improved its national financial monitoring legislation which, among other things, introduced an obligation to submit an ownership structure for all companies on an annual basis. The implementation of this obligation has been delayed until the adoption of a regulation approving the form and content of the ownership structure. Now that it has been adopted, companies have until 11 October, 2021, to submit the ownership structure with the state registrar.

The ownership structure is a free-form diagram showing all persons who directly or indirectly own the legal entity, alone or in association with others. It should indicate the extent of ownership by each of the owners, as well as the persons who, regardless of formal ownership, are in a position to exercise significant influence over the management or operations of the legal entity. In addition, a description of the exercise and nature of the ultimate beneficial owner’s decisive influence on the legal entity’s activities should be provided.

As a reminder, all legal entities will have to keep their ownership structure up to date, update it and submit a new document in case of any changes to the structure. Also from 2022, they will have to submit it annually within 14 days from the date of registration with the registrar, regardless of whether the company has had a change in structure.

Failure to submit or late submission of the above information to the state registrar is punishable by a fine (from UAH 17,000 to UAH 51,000) on the legal entity’s director or a person authorized to act on behalf of the legal entity (executive body).


If you would like more information on how to properly complete and submit ownership structure and information on ultimate beneficial owners, to learn about your company’s obligations in connection with the new financial monitoring rules, please contact us. SCHNEIDER GROUP legal experts in Ukraine are ready to advise you on the peculiarities of the current Ukrainian legislation in this field.

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