Beneficial Owner (UBO) Register in Latvia: Who Must Be Declared
August 6, 2026
Every legal entity registered in Latvia must declare its beneficial owners — in Latvian, patiesais labuma guvējs (PLG) — to the Register of Enterprises (Uzņēmumu reģistrs). A beneficial owner is the natural person who directly or indirectly owns more than 25% of the company's shares or voting rights, or who controls the company by other means. Not a holding company, not a nominee — a living human being.
This is not a one-off formality. UBO information must be included in the registration application at founding, and any change must be filed immediately — at the latest within 14 days from the day the company learns of it. The sanctions are real: refused filings, fines up to EUR 700 for the board member, striking off without a court, and criminal liability for false data.
For ordinary SMEs, the register matters most because banks rely on it during onboarding and periodic KYC reviews — and must report discrepancies between your answers and the register. An outdated UBO entry is one of the fastest ways to get a payment blocked.
Quick Summary
In Latvia, a beneficial owner (patiesais labuma guvējs, PLG) is a natural person who directly or indirectly holds more than 25% of a company's shares or voting rights, or otherwise controls it. All legal entities must declare their UBOs to the Register of Enterprises: at founding, within the registration application, and within 14 days of learning about any change. Non-compliance leads to refused filings, fines up to EUR 700 for the board member, simplified liquidation, and — for knowingly false data — criminal liability with up to one year of imprisonment. Latvia kept its UBO register publicly accessible free of charge even after the 2022 EU Court of Justice ruling.
Who Counts as a Beneficial Owner — the 25% Test
The definition comes from the Latvian AML law (Noziedzīgi iegūtu līdzekļu legalizācijas un terorisma un proliferācijas finansēšanas novēršanas likums — the NILLTPFN law). A beneficial owner is a natural person who:
- owns, directly or indirectly, more than 25% of the capital shares or voting stock, or
- directly or indirectly controls the entity by other means — shareholder agreements, the right to appoint the board, or de facto influence.
Note the wording: more than 25%, not "25% or more". A shareholder with exactly 25.0% fails the ownership test, though they may still qualify through control. Indirect ownership is traced through the chain: if you own 100% of an Estonian OÜ that owns 40% of a Latvian SIA, you are the SIA's beneficial owner.
For a single-owner SIA the answer is trivial — the founder is the UBO. Structures with several 20% shareholders or corporate owners require real analysis — and if no natural person qualifies at all, a special declaration is needed, as explained in the FAQ below.
When and How to File with the Register of Enterprises
UBO information travels with your other corporate filings. At incorporation, the registration application itself must state the beneficial owners — the Register will not register a company without it. Our guide to SIA registration documents covers the full founding package.
| Situation | Deadline | How |
|---|---|---|
| Founding a company | Together with the registration application | UBO section of the application form |
| UBO or manner of control changes | Immediately, at latest 14 days from learning of it | E-filing via ur.gov.lv with e-signature |
| Shareholder or board changes filed | In the same application | UBO data confirmed or updated |
| No UBO identifiable | With the relevant application | Declaration with written justification |
| Adding all nationalities of existing UBOs (2026 amendments) | By 31 December 2026 for persons without a Latvian personal code | Separate update filing |
For each UBO the Register records: name, personal identity code (or date of birth and identity document data for foreigners), nationality, country of residence, and the manner of control, including intermediaries in the chain. The 2026 amendments implementing the EU AML package add all nationalities a UBO holds and the documented extent of control. Filings are electronic with a qualified e-signature — see our guide to registering a company remotely.
Ownership Through Foreign Companies and Trusts
Foreign holding structures exempt no one — they just add paperwork. If a Latvian SIA is owned by a Cyprus holding owned by a BVI company, the Latvian company must trace the chain to the natural persons at the top and declare them, describing each intermediary link. The Register can ask for supporting documents: foreign registry extracts, share registers, trust deeds — often with translations.
Trusts are assessed through the people behind them: the settlor, trustee, protector, and beneficiaries can each qualify depending on who actually controls or benefits, and Latvian banks apply enhanced due diligence to trust structures almost automatically. One warning from our practice: multi-jurisdictional structures without a clear business purpose are the most common reason banks decline new Latvian companies — see our guide on opening a business bank account.
What Happens If You Do Not Declare
The sanctions escalate from inconvenient to existential.
| Consequence | Scale |
|---|---|
| Register refuses the filing | Company cannot be founded; later changes are not registered |
| Administrative fine | Warning or up to EUR 700 (140 fine units) for the board member, plus possible board disqualification for up to 3 years |
| Simplified liquidation | The company is struck off the register without court proceedings |
| Criminal liability for knowingly false UBO data | Up to 1 year of imprisonment; up to 2 years if substantial harm is caused (Criminal Law, Section 195.¹) |
| Banking consequences | Account applications refused, payments held, existing relationships reviewed or terminated |
Simplified liquidation is not theoretical: in the first enforcement wave, the Register struck off hundreds of companies. The banking consequence is even faster — a mismatch between your KYC questionnaire and the public register is flagged quickly, and onboarding or transactions stop until it is resolved.
Is UBO Data Public After the EU Court Ruling?
Yes — Latvia kept its register open. In November 2022 the EU Court of Justice ruled that unrestricted public access to UBO data disproportionately interfered with privacy rights, and several EU states closed their registers to the public. Latvia's Ministry of Justice and the Register of Enterprises decided the opposite: UBO data remains publicly available free of charge through the Register's information portal, and is even published as open data.
The 2026 amendments add one safety valve: from 1 July 2026, a beneficial owner facing a genuine threat to life, health, family, or property may request restricted public access. Authorities and AML-obliged entities such as banks retain full access regardless.
AML Basics for Ordinary Companies — and a Checklist for Foreign Founders
You do not need to be a bank to feel the AML law. An ordinary SIA is not an "obliged entity", but it lives inside the system the law creates. Expect your bank to send periodic KYC questionnaires (typically every 1–2 years), ask for source-of-funds documents when an unusual payment arrives, request contracts behind larger transactions, and screen you and your counterparties against EU, UN, and OFAC sanctions lists. Latvia's Financial Intelligence Unit (FID) coordinates enforcement, and sanctions rules bind businesses directly — a Latvian company may not transact with sanctioned persons, so screen counterparties before signing, not after.
Practical checklist for foreign founders:
- Identify every natural person holding more than 25% directly or indirectly before filing incorporation documents.
- Prepare identity documents and, for corporate shareholders, registry extracts proving the ownership chain.
- Declare UBOs in the registration application; diarise the 14-day deadline for future changes.
- Keep the register entry, the bank's KYC file, and your actual cap table permanently consistent.
- Be ready to show source of funds for the share capital and first working capital.
- Screen key counterparties against sanctions lists if you trade internationally.
Company size does not change these duties — micro and large companies file the same UBO data, though reporting differs by company category.
FAQ
What if no shareholder holds more than 25%?
First check control by other means: shareholder agreements, veto rights, the power to appoint or remove the board, or de facto decisive influence can each make someone a beneficial owner without a 25% stake. If no natural person qualifies under either test after exhausting all reasonable means, the company declares to the Register that a UBO cannot be identified, stating the justification. Expect follow-up questions from banks — a "no identifiable UBO" entry is a standard enhanced-due-diligence trigger.
How quickly must UBO changes be reported in Latvia?
Immediately, and no later than 14 days from the day the company learns of the change. The clock starts at knowledge, not at the underlying event — but for share transfers the company normally learns on the transfer date, so treat 14 days from the deal as your practical deadline. Changes are filed electronically with a qualified e-signature, and UBO data must also be confirmed whenever you file shareholder or board changes.
Can anyone see the beneficial owners of my Latvian company?
Yes. Latvia deliberately kept UBO data publicly accessible after the November 2022 EU Court of Justice ruling, free of charge through the Register of Enterprises portal. Visible data includes the UBO's name, birth month and year, nationality, country of residence, and manner of control. From 1 July 2026, an owner facing a documented threat to life, health, family, or property can request restricted public access — but authorities and banks always retain full visibility, so restriction never hides you from KYC checks.
Why does my bank keep asking about beneficial owners and source of funds?
Banks are obliged entities under the Latvian AML law: they must verify beneficial ownership independently, compare it against the public register, and report any discrepancy. They must also understand where your money comes from, so requests for contracts or invoices behind incoming payments are standard practice, not a sign of suspicion. Answer quickly and consistently with your registered UBO data; ignoring the questions leads to blocked payments and, eventually, a terminated account.
Keep Your UBO Register and Bank File in Perfect Sync
CORVUS ACCOUNTING & TAX prepares UBO declarations, files changes with the Register of Enterprises within deadline, and helps founders assemble the ownership-chain documents banks actually accept.
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