UBO stands for Ultimate Beneficial Owner. An UBO is a person who is the ultimate owner of or has control over an organization. This can also be multiple people.
ING applies the following types of UBO:
"}},{"componentType":"accordion","accordionList":[{"title":"1. UBO based on shareholding","richBody":{"value":"A person who directly or indirectly holds more than 25% of the shares.
"}},{"title":"2. UBO based on voting rights","richBody":{"value":"A person who directly or indirectly holds more than 25% of the voting rights in the general meeting.
"}},{"title":"3. UBO based on economic interest","richBody":{"value":"A person who directly or indirectly holds more than 25% of the economic interest (entitlement to profit or reserves).
"}},{"title":"4. UBO based on factual control","richBody":{"value":"A person who can exercise significant influence in a way other than those mentioned above, but is not a director. This includes:
NOTE: Only relevant if no UBO has been identified based on one of the four types above.
These are the statutory directors, partners or members. If your organisation is registered with the Chamber of Commerce (KVK), these individuals are listed there as such. This may also include roles such as chairperson, treasurer, or secretary.
"}}]},{"componentType":"paragraph","richBody":{"value":"Are there UBOs with more than one type of interest? Then choose the first interest that applies from above. For example: if a person qualifies as a UBO based on both shares and voting rights, you only need to report this person to us as a UBO based on shares.
An Ultimate Beneficial Owner is not the same as a Legal Representative or Endorsee. Click here for more information on how to update a Legal Representative or Endorsee.
"}},{"componentType":"sectionTitle","title":"Why do I have to provide my UBO's?"},{"componentType":"paragraph","richBody":{"value":"ING is required under the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and the Financial Supervision Act (Wft) to record the UBOs of our business customers and to keep this information up to date. This is to ensure the integrity of the financial sector and of ING itself, now and in the future. For this reason, it is important that we have the current information of your representatives and UBOs.
Since March 2022, most businesses are required to register their UBOs (Ultimate Beneficial Owners) in the UBO register at the Chamber of Commerce (KvK). This provides transparency and helps combat fraud, money laundering, and terrorism financing. Have you filled in the UBO register yet? Check with the KvK to see if this is necessary for your business. If you are required to submit UBOs to the UBO register and have not yet done so, please do this first, otherwise, you cannot open a business account.
"}},{"componentType":"accordion","accordionList":[{"title":"Why do I have to report my UBOs to both the Chamber of Commerce (KVK) and ING?","richBody":{"value":"In addition to having to enter the UBOs in the UBO register of the Chamber of Commerce (KVK), you also have to pass them on to us using the UBO form. Unfortunately, ING is not allowed to copy this information from the Chamber of Commerce (KVK).
"}},{"title":"Why do I have to register my UBOs with ING but not with the Chamber of Commerce (KVK)?","richBody":{"value":"ING has a duty to investigate all its customers under the Money Laundering and Terrorist Financing (Prevention) Act (Wwft). It is therefore possible that you do not have a registration obligation for the UBO register, but that ING does ask you to provide the UBOs. This is the case, for example, with homeowners associations (VVE) in the Netherlands.
"}}]},{"componentType":"sectionTitle","title":"Who are the UBOs of my organisation?"},{"componentType":"paragraph","richBody":{"value":"Your organisation determines who the UBOs are based on this information. ING or the Chamber of Commerce (CoC = KVK) cannot advise you on this.
Information on determining UBOs from the Dutch Chamber of Commerce
"}},{"componentType":"accordion","accordionList":[{"title":"Church / Religious Denomination","richBody":{"value":"Note: if the church / religious denomination is affiliated with an Umbrella Organisation, then you take the Umbrella Organisation as the starting point for the UBO determination.
"}},{"title":"Sole proprietorship","richBody":{"value":"If you have received a request by letter to provide UBOs as a sole proprietorship, it seems that you are not registered correctly in our administration. Please send an email with your organization name, full address including zip code and KVK-number to: updatengegevens@ing.com.
"}}]},{"componentType":"sectionTitle","title":"What do I need to complete the UBO form?"},{"componentType":"paragraph","richBody":{"value":"It is important that the legal representatives known to ING are also listed as directors at the Chamber of Commerce (provided that there is a Chamber of Commerce registration). If this is not (yet) the case, we cannot process the submitted UBO form.
The following information is required (at least) to complete the form:
The term entity is used to indicate an existing legal person/organisation or company. In this case, we are talking about a legal entity.
"}},{"title":"I want to clarify the structure of my organisation with an organisational chart. How do I make an organisational chart?","richBody":{"value":"Please see our organisational chart page for more information.
"},"textLinks":[{"url":"/en/business/customer-service/kyc/sumitting-an-organisational-chart","text":"Go to the organisational chart page"}]},{"title":"What is a limited legal capacity association?","richBody":{"value":"An association with limited legal capacity is also called an informal association. For this legal form, a KVK registration is not required. This could be, for example, a local social club or a local music club.
"}},{"title":"What is a fully legal capacity association?","richBody":{"value":"An association with full legal capacity is also called a formal association. For this legal form, a Chamber of Commerce registration is required.
"}},{"title":"Do I have to fill in a UBO form as a sole proprietorship or self-employed person?","richBody":{"value":"If you have received a request by letter to provide UBOs as a sole proprietorship, it seems that you are not registered correctly in our administration.
Please send an e-mail to: updatengegevens@ing.com with
If you have any additional questions about the UBO form or the UBO declaration, we will contact you by email at the email address with which the form or declaration was submitted. The email address will not be used for commercial purposes.
Please note: if you submit UBO declarations for multiple organisations, please submit them in separate emails (with the correct reference).
"}},{"componentType":"accordion","accordionList":[{"title":"Has my UBO form been received by ING?","richBody":{"value":"Note: You will only receive a confirmation of receipt if you use our e-mail address updatengegevens@ing.com, stating the reference we mention in the letter or stating your Chamber of Commerce (KVK) number. It is useful to know that the form has arrived safely.
"}},{"title":"Do I need to deregister a person who is no longer a UBO?","richBody":{"value":"If there is a change in the ownership structure, we ask you to update the UBO information.
Via “Manage Authorisations” in MINGZ, you can deregister a person as a UBO.
Another option is to complete the UBO form and email it to updatengegevens@ing.com, including your Chamber of Commerce (KVK) number. The current UBO information will then be overwritten with the newly provided details.
Sending it by post is possible, but we would prefer not to. The processing time will be longer and it is less good for the environment. In addition, you will not receive a confirmation of receipt if you send the form by post.
Do you still want to send it by post? Send the details, stating the reference that we mention in the letter or your Chamber of Commerce number, to:
ING
Antwoordnummer 40620
8900 TA Leeuwarden
Yes, an ING employee can help you explain the question. However, we cannot help you determine the UBOs. Click here for the options to contact us. For example, via Chat, then you will be redirected and have chat contact with an ING employee. Or make an appointment at the office.
"}},{"title":"Can I also e-mail questions to updatengegevens@ing.com?","richBody":{"value":"This e-mail address cannot be used for questions. E-mails with questions will not be processed.
"}}]},{"componentType":"sectionTitle","title":"Who is authorised to sign the UBO form?"},{"componentType":"paragraph","richBody":{"value":"The UBO form can be signed by:
For more details, you can refer to the page “Who can sign the UBO declaration?” on the ING website.
"}},{"componentType":"sectionTitle","title":"How do I know if I have to provide UBO information?"},{"componentType":"paragraph","richBody":{"value":"If we need the UBO data of your company or organisation, for example because we do not have it yet or because it is outdated, we will send you a letter about it. We also use e-mail and prepare a message in the inbox of My ING Business.
It is therefore important that your correspondence address of your company or organisation is stated correctly and that we can reach you by e-mail.
"}},{"componentType":"accordion","accordionList":[{"title":"I have received multiple letters, do I need to update the information for each organisation?","richBody":{"value":"ING is legally required to record who the UBOs are for our business customers. This means that we want to receive the data of each organisation separately from you if you are involved with multiple organisations with a Business Account at ING.
"}},{"title":"My organisation has multiple account numbers, is submitting one form sufficient?","richBody":{"value":"On the UBO form you only need to provide one account number. Despite the fact that you only need to fill in one account number on the UBO form, the UBO's are recorded at customer/organisation level. This means that the UBO's for all account numbers under your organisation are updated.
"}},{"title":"I still have (a copy of) a previously submitted UBO form. Can I send it again?","richBody":{"value":"It is possible that your previously submitted UBO form does not meet the requirements of the most recent legislation. We would like to ask you to fill out the form again and send it to us.
"}},{"title":"The board of my organisation will change in 1 to 2 months. Do I still have to submit the UBO form now?","richBody":{"value":"Yes, we would like to receive the current information from you. As soon as a change occurs, you can report these changes to us again.
"}},{"title":"Do I have to submit my UBO's annually?","richBody":{"value":"We may request UBO's annually. It may also happen that there is a longer period of time between them. We can make the request by letter, as a request via an inbox message or via a message in My ING Business (via Web or ING App).
"}},{"title":"Can I sumit my UBO's via My ING Business?","richBody":{"value":"Yes, via Service, Manage authorisations, UBO.
"}}]},{"componentType":"sectionTitle","title":"I have received a reminder, has the form been received correctly?"},{"componentType":"paragraph","richBody":{"value":"Due to the busy processing of the forms that we receive, the processing may take longer than you are used to from us. It may also happen that your response and the reminder cross each other. If you have already responded, you can consider the reminder as not sent.
"}},{"componentType":"sectionTitle","title":"What happens if I don't provide the requested information to ING on time?"},{"componentType":"paragraph","richBody":{"value":"Rest assured, we will not just block your Business Account. You will receive a number of reminders. If you do not provide us with the requested information, we will unfortunately have to block your account(s). This means that you will no longer be able to make payments; You can only receive amounts. Ultimately, failure to provide the requested information may cause ING to reconsider its banking relationship with you.
"}},{"componentType":"accordion","accordionList":[{"title":"Can ING block my account just like that?","richBody":{"value":"ING is required by law to update the data of our business customers. As soon as information is missing, ING may block your account.
"}},{"title":"Can my G account also be blocked?","richBody":{"value":"The letter you have received does not relate to the G Account, but to the Business Account(s) you have in your possession.
"}},{"title":"What should I do if I disagree with this decision? Can I make a complaint?","richBody":{"value":"We'd love to hear your thoughts. Personal contact is a great way to talk to you. You can submit or report your complaint in various ways:
You can call us on 020 22 888 22
You can chat with us (via My ING). Then you will have direct contact with one of our employees
🛈 We offer the English information on ING.nl as an additional service. This information was translated from Dutch, and in case of any inconsistency, the original Dutch text shall prevail.
"}}]}}}