Overview, definitions, thresholds

Beneficial ownership data in Ukraine has been publicly available as open data in the Unified State Register of Legal Entities and Individual Entrepreneurs (USR) since 2017.

Ukrainian law refers to ‘controllers’ (контролери) as opposed to ‘founders’ (засновниками) to differentiate beneficial ownership from legal ownership/shareholding. ‘Founders’ can be legal entities or natural persons.

A beneficial owner of a legal entity is a natural person who directly or indirectly:

  • Has the right to execute decisive influence on the management or economic activity of a legal entity
  • Has decisive influence on the composition and decisions of the entity’s managing body
  • Has at least 25% of shares or voting rights of the entity

Nominees and agents of such rights cannot be named as beneficial owners.

Exclusions and exemptions

If the ‘founders’ of a legal entity are both natural persons and the beneficial owners of the entity, then the law relieves them from the duty to separately declare beneficial ownership (as such information is collected about the founders already).

Joint stock companies and listed companies are not obliged to report their beneficial ownership data in the USR, however they must report owners of 10% and above of company shares to the Stock Market Infrastructure Development Agency (SMIDA).

Finally, the following entities are excluded from the scope of the law: civic formations, attorney associations, trade chambers, associations of co-owners of apartment buildings, religious organisations, state authorities, local self-government bodies and their associations, state and municipal enterprises/establishments/organisations.

Data availability and license

The Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations has data publicly and freely available as bulk download, via a daily zip file (unstructured data).

The data is licensed under Creative Commons Attribution (cc-by).

In order to conduct a record search via a simple website interface, one has to file a request and pay a small fee.