Updating UBO Information in 2026 – Is It Mandatory for Everyone?

On 3 December 2025, the Saeima adopted Amendments to the Law on the Prevention of Money Laundering and the Financing of Terrorism and Proliferation (hereinafter – the Amendments), which clarify the procedures for providing and accessing information regarding beneficial owners.

The changes are also linked to developments in the European Union’s regulatory framework in the field of financial crime prevention. In particular, they implement the requirements arising from Directive (EU) 2024/1640 of the European Parliament and of the Council, which aims to strengthen the protection of the financial system against money laundering, whilst improving the quality of information on the beneficial owners of legal entities.

According to the explanatory memorandum to the bill, the Amendments aim to improve the completeness of beneficial owner data, as well as to ensure a balance between the transparency of corporate ownership structures and the protection of natural persons’ privacy.

1. One of the key aspects of the Amendments is the expansion of the scope of information that must be disclosed regarding beneficial owners in the Register of Enterprises.

In future, legal entities will be required to disclose:

• all the beneficial owner’s nationalities, if the person has more than one;
• information on the extent of control exercised by the beneficial owner over the company.

These requirements have been introduced with the aim of ensuring more accurate information on the ownership structure of legal entities, which is essential in the process of preventing financial crime and conducting customer due diligence.

The amendments also provide for a more detailed approach to describing the beneficial owner’s control. The register will have to specify not only the person who benefits from the legal entity’s activities, but also information on how this control is exercised.

In international practice, the identification of beneficial owners is based on the principle that it is necessary to identify not only the legal owner but also the person who actually controls the legal entity. As emphasised by the Financial Action Task Force (an intergovernmental organisation that sets global AML/CFT standards), the beneficial owner is a natural person who ultimately controls the legal entity or benefits from its activities, regardless of whether this control is exercised directly or indirectly.

The FATF guidelines state that legal entities may be used to conceal the true owners or controllers, particularly in cases where complex ownership structures or intermediary companies in different jurisdictions are used. Therefore, in the process of identifying the beneficial owner, it is essential to analyse not only shareholdings but also other control mechanisms, such as voting rights, contractual arrangements or actual influence over the company’s decision-making.

More precise information on control mechanisms will enable competent authorities and entities subject to the Law on the Prevention of Money Laundering and the Financing of Terrorism and Proliferation (hereinafter – the AML Law) to better assess the ownership structures of legal persons. This approach is considered a key tool in the prevention of financial crime, as it allows for the identification of persons who actually control the activities of a legal entity, even if they are not formally designated as owners but who in fact have a decisive influence over the company.

In turn, information on the beneficial owner’s nationality is particularly important in assessing sanctions risk. Individuals may be linked to multiple jurisdictions, and in some cases sanctions or high-risk factors may be directly linked to a specific nationality. If only one nationality is indicated, there is a risk that other links to high-risk countries will go unnoticed.

In practice, this may be important, for example, in a situation where the beneficial owner of a company is a person with dual nationality – one from a Member State of the European Union and the other from a third country. If only one nationality is indicated, a link to a jurisdiction subject to international sanctions or considered a high-risk country may not be identified.

Consequently, more detailed information on beneficial owners helps both the competent authorities and entities subject to the AML Law to identify and manage potential financial crime and sanctions risks more effectively.

The legislator has also provided for mechanisms that allow information on beneficial owners to be updated automatically in certain cases.

For example, if a beneficial owner has been identified using a personal identification number issued in Latvia, information on nationality can be obtained from the Register of Natural Persons. Similarly, in cases where control over a company derives solely from the holding of shares, the Register of Enterprises may use already available data on the owners of the legal entity.

This solution reduces the administrative burden on companies and allows some information to be updated without the need for additional submissions.

2. A significant change provides for the possibility, in certain cases, to restrict public access to information on beneficial owners.

The relevant provisions will be included in Section 18.³ of AML Law, which will come into force on 1 July 2026.

Under this provision, the beneficial owner may apply to the Register of Enterprises to restrict public access to information if there is a risk that such public access could pose a threat to:

• a person’s life or health;
• family members;
• a person’s property.

The application must include a description of the situation, justification of the potential threat, and available evidence. The Register of Enterprises will assess the information submitted and decide on restricting access. Designated staff at the Register of Enterprises will be trained for this purpose to ensure a consistent and high-quality approach to the assessment of the evidence submitted, including to determine whether, in a specific case, there are sufficient grounds to restrict public access to information on the beneficial owner. At the same time, it cannot be ruled out that, in more complex or sensitive cases, the competent security and defence authorities may also be involved in the assessment process.

In European practice, this option has been used, for example, by persons operating in sectors with an increased risk to physical security, or who have previously been subjected to threats or blackmail, or persons whose place of residence or property could pose security risks if publicly identified.

International practice confirms that restricting access to information on beneficial owners is an exceptional measure.

It is expected that detailed guidelines will be developed and published, clarifying both the criteria for applying this option and the scope and type of evidence required to justify withholding information regarding beneficial owners. Such guidelines will be essential to ensure consistent practice and minimise interpretation risks for both the staff of the Register of Enterprises and the legal entities themselves.

It should be noted that even if the information is not disclosed publicly, it will still be available to competent state authorities and entities subject to the AML Law for customer due diligence purposes.

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For the majority of legal entities, the above-mentioned changes will not create any significant new obligations.

However, in some cases it may be necessary to update or clarify information regarding beneficial owners.

Accordingly, companies are advised to:

• ascertain the nationality of all beneficial owners;
• clarify the information regarding the nature and extent of control;
• submit updated information to the Register of Enterprises where necessary.

The amendments to the law set out several deadlines relating to the updating of information on beneficial owners.

1 April 2026
Part of the regulation comes into force. Requirements for identifying beneficial owners are clarified, the obligation to document control mechanisms is reinforced, and the transparency of legal entities is improved.

1 July 2026
Section 18.³ of the AML Law, which sets out the procedure for restricting access to information, comes into force, as does the part of the Amendment that expands the information to be disclosed regarding beneficial owners.

10 July 2026
By this date, the Register of Enterprises will automatically update information on the nationalities of beneficial owners in cases where a person has been identified using a Latvian personal identification number.

31 December 2026
If the beneficial owner is not identified by a Latvian personal identification number, the legal entity must submit information regarding that person’s nationality or nationalities by this date.

31 December 2026
By this date, the Register of Enterprises may automatically register information regarding the extent of control exercised by the beneficial owner in cases where such control arises solely from the status of a member, shareholder or sole proprietor.

! Companies are advised not to wait until 1 July 2026, but to review their beneficial ownership structure now and prepare information on the extent of control and nationality in good time !