Alert: Update on implementation of the UBO Register

The last of the implementing Decrees on the establishment of the UBO Register has been finally published[1] on October 9, 2023.

As of October 10, 2023, companies will have sixty days (i.e., within December 11, 2023) to file the related communication on their beneficial ownership.

The relevant filings shall be made through the dedicated platform provided by the Register of the Enterprises (so called “DIRE” system).

The relevant communications shall be made by the directors of companies, which shall disclose and file the following main data/information on beneficial ownership, by means of their digital signature device:

  • identification data and citizenship of the natural person(s) indicated as beneficial owner(s) and information related to the relevant company (g., corporate name, date of incorporation, and so on);
  • the criterion pursuant to which the individual(s) may be identified as beneficial owner(s) of the company;
  • (if applicable) any circumstances regarding the basis for exclusion of access to information on beneficial ownership, as well as an email address for further contact.

In addition, directors shall declare that they are responsible for and aware of the penalties provided by Italian criminal law, as well as specific laws on the falsification of documents and statements.

Filings with the UBO Register are subject to payment of standard secretarial fees and are exempt from stamp duties.

Penalties for failure to comply with the disclosure requirements on beneficial ownership range from EUR103 to EUR1,032 per director. Furthermore, additional obligations and additional and greater responsibilities apply to businesses listed among entities obligated to perform know-your-customer due diligence (e.g., banks, insurance companies, cryptocurrency brokers, and real estate agencies)[2].

For more information on the UBO Register, please refer to our articles at the following links:

We remain at your disposal for any clarification you may need.


[2] Please refer to section 3 of Legislative Decree No. 231/2007 for a complete list of such entities.

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