What a Beneficial Owner (UBO) Is
The beneficial owner (Ultimate Beneficial Owner — UBO) is the real individual who ultimately owns or controls a company. Not the nominee shareholder, not the director, but the person in whose pocket the money and decisions end up.
In many cases, the beneficial owner matches the shareholder registered in the state register. But when a company is owned by another company, which is owned by a trust, which is managed by an offshore entity, tracking down the actual individual can get complicated. That is exactly why the UBO declaration exists.
Core rule: if an individual directly or indirectly owns more than 25% of the share capital or voting rights, or exercises control over the company by other means, they are a beneficial owner and must be declared at ASP.
Why UBO Declaration Became Mandatory
Moldova passed Law No. 308/2017 on preventing money laundering and terrorist financing, amended in 2022-2023 to require all legal entities to declare beneficial owners.
The reason: Moldova is monitored by MONEYVAL (Council of Europe's anti-money-laundering committee) and FATF. Without a working UBO register, the country risks landing on the international grey list, which affects banking transactions, foreign investment, and credit ratings.
In practice, the UBO register helps:
- Banks running KYC for corporate account opening
- Investigative journalists (opaque-capital businesses)
- Investors before acquiring a company
- Authorities in tax evasion or money laundering cases
Who Must Declare the Beneficial Owner
The obligation applies to all legal entities registered in Moldova:
- SRLs — any size
- Joint-stock companies (SA), including listed ones
- Sole proprietorships and state-owned enterprises
- Cooperatives, public associations, foundations
- Branches and representative offices of foreign companies
- Any other legal form registered in the state register
Partial exception: the state and territorial-administrative units when they own public companies — in these cases the institution is declared, without searching for an individual behind it.
Deadline and Penalties
The original deadline was December 31, 2025, but it was extended by one year — to December 31, 2026 — for all companies that haven't declared yet. Check confirmation on the ASP website before acting, as deadlines can change.
Penalties for non-compliance (Contravention Code, art. 263):
- Individual (director): from 3,000 to 7,500 MDL
- Legal entity: from 15,000 to 37,500 MDL
Beyond fines, companies without UBO declaration may face:
- Blocks on opening or maintaining bank accounts
- Issues participating in public procurement (MTender)
- Refusal of licenses or permits
What Information Is Declared
The UBO declaration contains, for each beneficial owner:
- Full name
- IDNP (or ID document for foreign citizens)
- Date of birth
- Citizenship
- Residential address
- Basis for qualifying as UBO (ownership percentage, type of control)
- Date on which the person became UBO
If no UBO can be identified through 25%+ ownership, the person exercising effective control is declared (usually the main director or CEO).
How to Declare the UBO (Step by Step)
Step 1: Identify the real UBOs. For a simple company with 1-2 individual shareholders, it's direct — the shareholders are the UBOs. For more complex structures (parent companies, holdings, offshore), you need to trace the chain down to the final individuals.
Step 2: Prepare documents.
- Passport or ID of each UBO (copy)
- General shareholders' meeting resolution (confirming UBO identification)
- Standard declaration form (available on the ASP website)
Step 3: Submit the declaration to ASP. Three options:
- Online on servicii.gov.md with digital signature or MobiSign
- At an ASP physical office
- Through a notary (especially if there are disputes about control structure)
Step 4: Confirm registration. After processing, you receive a confirmation document. Check on the company's extract that UBOs appear correctly in the state register.
Step 5: Update when things change. Any change to UBOs (sale of shares, change of control, etc.) must be declared within 30 days.
Examples: What UBO Looks Like in Practice
Simple case (single-shareholder SRL): Ion Popescu owns 100% of "ABC Construct SRL". Ion is the UBO. Done.
Medium case (SRL with two shareholders): Maria (60%) and Dumitru (40%) own a company. Both are UBOs (over 25%).
Complex case (holding): "Moldovafin SRL" is owned by "Balkan Holdings Ltd" (Cyprus), owned by a trust managed by a Malta firm, whose beneficiaries are brothers Alexandru and Vadim Cojocaru. Declared UBOs: Alexandru and Vadim.
Case without identifiable UBO: A foundation with many donors and no clear owner — declared UBO: the board chairman who exercises operational control.
How to Check a Moldovan Company's UBO
After declaration, UBO data is partially public — in Moldova, aggregate information (name, ownership percentage) is accessible, while sensitive data (address, full ID number) remains restricted to authorized institutions.
On Datero.md you find, for each company:
- Officially registered founders and shareholders
- Current directors
- Affiliation network — other companies of the same people
- When UBO data is public, it appears on the company page
This lets you quickly verify who "stands behind" any company before signing a contract or investing. See our due diligence guide for the full approach.
Frequently Asked Questions
I'm an employee, not a director. Do I need to do anything?
No. The obligation falls on the director and the legal entity. If you're only on payroll, you have nothing to declare.
My company has never operated. Do I have to declare?
Yes, as long as it exists as a legal entity in the state register. Inactive companies must declare UBO too.
I declared in 2023 and nothing has changed since. Do I re-declare?
No, if the data is identical. Re-declaration is needed only when UBOs or ownership percentages change.
Is the director automatically the UBO?
No. The director runs the company; the UBO ultimately owns or controls it. They can overlap, but not necessarily. Only if no other UBO is identifiable (all shareholders under 25%), the director is declared as UBO through "exercised control".
Which CAEM code do I need for UBO declaration?
CAEM code doesn't matter. The obligation depends on legal form, not on activity.
Check a Company's UBO Status Now
On Datero.md you look up any company by IDNO or name and see shareholders, directors, and the ownership structure from the state register. Free and instant — shows exactly who you're dealing with.