The deadline for fulfilling the duty of entering data on actual owners of companies into the Register of data on actual owners of companies is approaching.

The amendment of act no. 304/2013 Sb., on public registers of persons and legal entities, effective from 1 January 2018, has introduced Registration of data on actual owners. All legal entities registered in the trade register must enter their actual owners in this register, by 1 January 2019. Other legal entities registered in other public registers have this duty by 1 January 2021. The register of the given data is non-public.

How to assess, who the actual owner is, says act no. 253/2008 Sb., on some arrangements against legalization of proceeds from criminal activity and financing of terrorism (the so-called Anti-Money Laundering act). It is a person, which has the occasion to exercise directly or indirectly decisive influence in a legal entity, trust fund or another legal arrangement without legal personality.

A company must identify the actual owner and record current data for his identification and verification his identity. There are no sanctions impending in case of failure to communicate or substantiate the information. Such entities may get into problems, though, when requesting provision of financial services, subsidies, or in case of public procurement.