The Dutch commercial register — Kamer van Koophandel (KvK) — records who holds a directorship and what authority that person carries. A second register, the UBO register maintained by the same chamber, records who ultimately controls or owns the entity. These two layers answer different questions, and they do not always point to the same person.
Control in a Dutch company is distributed across at least three planes: the management board, the supervisory board (where one exists), and the shareholder register. What the KvK shows, what it withholds, and where the chain stops — that is the subject of this page.
What the KvK showsDirectors (bestuurders), authorised signatories, and their scope of authority — individually authorised, jointly authorised, or limited. Source: Kamer van Koophandel · verified 2026-10-14 UBO registerThe Dutch UBO register (UBO-register) is held by the KvK and records natural persons with an interest of 25 % or more, or equivalent control. Source: Kamer van Koophandel · verified 2026-10-14 Access condition — UBO registerFollowing CJEU judgment C-37/20, public access to UBO data is restricted. Access requires a demonstrated legitimate interest; the mechanism and scope of disclosure are set by the Wet toezicht trustkantoren 2018 and implementing regulation. Source: KvK / Wwft · verified 2026-10-14 What the KvK does not showShareholder identity and share distribution in a BV are not published in the KvK extract; they appear in the notarial deed of incorporation and subsequent deeds of transfer, held at a civil-law notary.Who controls a Dutch BV: the three layers the record covers
A besloten vennootschap (BV) separates management authority from economic ownership. The KvK extract (uittreksel) names the managing director or directors, states whether each acts alone or jointly, and records any limitation on authority registered against third parties. That is the management layer.
The supervisory board (raad van commissarissen), where one exists, is also registered. Its members appear in the extract with their appointment dates. Supervisory board members do not bind the company externally, but their presence signals a governance structure that constrains management.
The shareholder layer is different. Dutch law does not require a BV to file its shareholder register with the KvK. Shareholders appear in the notarial deed of incorporation and in subsequent notarial deeds each time shares are transferred. Those deeds are held by the notary who executed them, not by a public register. The KvK extract does not name shareholders.
This separation is structural, not incidental. Establishing who owns the shares requires a different source — and a different access path.
The UBO register: what it records and what access requires
The UBO register was established under the Fourth Anti-Money Laundering Directive and implemented in the Netherlands through the Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft). Every legal entity incorporated in the Netherlands must register its ultimate beneficial owners — natural persons holding more than 25 % of shares, voting rights, or equivalent control.
The register records: full name, month and year of birth, nationality, country of residence, and the nature and size of the interest held. It does not record the residential address in the public-facing extract.
Access changed materially after the Court of Justice of the European Union issued its judgment in joined cases C-37/20 and C-601/20 on 22 November 2022. The court held that unrestricted public access to UBO data is incompatible with the right to privacy under the EU Charter. The Netherlands suspended general public access. Access is now available to competent authorities, obliged entities under the Wwft (financial institutions, notaries, accountants), and persons who can demonstrate a legitimate interest.
What constitutes a legitimate interest is assessed case by case. A cross-border acquisition or due diligence process may qualify; the outcome is not guaranteed in advance.
Shareholder rights and what the register records about them
The KvK extract records the legal form of the entity, its registered address, its statutory purpose, and its management structure. It does not record the rights attached to individual share classes, the existence of a shareholders' agreement, or any contractual restriction on share transfer.
A BV may issue multiple classes of shares with different voting weights or profit entitlements. Those rights are set in the articles of association (statuten). The statuten are filed with the KvK and are publicly accessible. They define the framework — quorum requirements, approval thresholds for major decisions, pre-emption rights. They do not show who holds which class.
Pledges and usufructs over shares are recorded in the notarial deed but are not systematically visible in the KvK extract unless the voting right has been transferred to the pledgee or usufructuary and that transfer has been registered.
A shareholders' agreement (aandeelhoudersovereenkomst) is a private contract. It does not appear in any register. Its existence, and its effect on control, cannot be established from public sources.
Deeds, notarial records, and the chain of title
Each transfer of shares in a BV requires a notarial deed of transfer (akte van levering). The notary who executed the deed holds the original. The company's own shareholder register (aandeelhoudersregister) records current ownership, but that register is maintained by the company itself and is not filed with any public authority.
Establishing the current shareholder requires either: access to the company's own register (which requires the company's cooperation), or reconstruction from the chain of notarial deeds. The latter is possible where the notary can be identified and access can be arranged — but it is not a public-access process.
For entities incorporated before the current KvK digital system, older records may exist only in paper form at the chamber's archive or at the notary's office.
Where the chain of control runs through a foreign entity
A Dutch BV may be owned by a foreign holding company. In that case, the KvK records the foreign entity as the shareholder in the deed of incorporation — but only if that information was provided at incorporation. The KvK does not verify or update the shareholder layer after incorporation.
The UBO register is intended to pierce this structure: the natural person behind the foreign holding must still be registered as UBO. But the accuracy of that registration depends on the self-reporting obligation of the entity. The register records what was declared, not what was independently verified.
Where the chain runs through a jurisdiction with limited disclosure — a Delaware LLC, a Cayman Islands exempted company, or a trust — the UBO registration may name a nominee or a trustee rather than the economic owner. The register records the declaration; it does not resolve the underlying structure.
The limit of what the sources allow
The KvK extract establishes the management layer with precision: directors, their authority, and the supervisory board. That layer is reliable and current.
The UBO register establishes the declared beneficial owner. Access requires a demonstrated legitimate interest. The content reflects what the entity reported; it is not independently audited. A discrepancy between the declared UBO and the actual economic owner is not detectable from the register alone.
The shareholder layer — who holds which shares, in what class, subject to what restrictions — is not in any public register. It sits in notarial deeds and in the company's own records. Establishing it requires a source beyond the KvK.
The statuten establish the governance framework but not its application. A shareholders' agreement that modifies control in practice does not appear anywhere in the public record.
The ceiling of what the sources allow is stated before payment.
Where the sources disagree
The KvK extract and the UBO register may name different persons in a control role. A director with sole authority to bind the company is not necessarily the UBO; a UBO with a 30 % interest may hold no management position at all.
The statuten may grant a supervisory board veto rights over major transactions. If the supervisory board is not registered — or if its composition has changed and the update has not been filed — the extract understates the governance constraint.
Older KvK records may reflect a management structure that was superseded by a private amendment to the shareholders' agreement. The register does not capture that change.
Where the KvK extract, the UBO registration, and the statuten point in different directions, the divergence is itself a finding. It is recorded as such in the report.
What is included at each tier
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €1,350 | KvK extract (current): directors, authority scope, supervisory board members, registered address, legal form, statutory purpose. Statuten on file. Entity status (active / dissolved / in liquidation). | UBO register data. Shareholder identity. Notarial deed chain. Foreign holding structure. Shareholders' agreement. |
| Standard | €2,850 | Everything in Signal. UBO register query with legitimate-interest access request. Statuten analysis: share classes, quorum thresholds, pre-emption rights, approval requirements. Identification of notary of record for incorporation deed. Summary of governance framework. | Reconstruction of full notarial deed chain. Shareholders' agreement content. Foreign entity structure beyond first layer. |
| Extended | €6,300 | Everything in Standard. Reconstruction of share transfer chain from notarial records where accessible. Analysis of foreign holding entity at first layer (jurisdiction, registration status, publicly available filings). Cross-reference of UBO declaration against available corporate records. Identification of structural gaps and divergences across all sources. Written analytical summary with source citations. | Content of shareholders' agreements. Verification of UBO declaration accuracy beyond available records. Legal advice on enforceability or transaction risk. |
FAQ
Does the KvK extract show who owns the shares in a Dutch BV? No. The KvK extract records directors and their authority. Shareholder identity in a BV is recorded in notarial deeds and in the company's own shareholder register, neither of which is publicly filed. The extract does not name shareholders.
Is the Dutch UBO register publicly accessible? General public access was suspended following the CJEU judgment of November 2022. Access is available to competent authorities, Wwft-obliged entities, and persons demonstrating a legitimate interest. The access mechanism and the scope of data disclosed are determined by the applicable regulation.
What does the UBO register actually record? It records the natural person's name, month and year of birth, nationality, country of residence, and the nature and approximate size of the interest. Residential address is not included in the accessible extract. The register records what the entity declared; it is not independently audited.
Can a shareholders' agreement affect control without appearing in any register? Yes. A shareholders' agreement is a private contract. It does not appear in the KvK, the UBO register, or the notarial deed. Its existence and effect on actual control are not detectable from public sources.
What happens when the chain of ownership runs through a foreign entity? The KvK records the foreign entity as shareholder at the point of incorporation. The UBO register is intended to identify the natural person behind the foreign holding. Where the foreign entity is in a low-disclosure jurisdiction, the UBO declaration may not resolve the underlying structure. The report identifies the point at which the chain becomes opaque.
How current is the KvK extract? The KvK extract reflects the state of the register at the moment of retrieval. Entities are required to file changes within a statutory period, but the register records what has been filed, not what has occurred. A management change that has not yet been filed will not appear.
Sources
Kamer van Koophandel (KvK) — https://www.kvk.nl — extracted 2026-10-14
KvK UBO-register — https://www.kvk.nl/producten-bestellen/ubo-register/ — extracted 2026-10-14
Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) — https://wetten.overheid.nl — verified 2026-10-14
CJEU judgment C-37/20 and C-601/20, 22 November 2022 — https://curia.europa.eu — verified 2026-10-14
Burgerlijk Wetboek Boek 2 (BW 2) — Dutch Civil Code, Book 2 — https://wetten.overheid.nl — verified 2026-10-14
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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Elena Moretti — Partner, Continental Europe, VLO Law Firm
