Following the obligation for companies to keep a register of beneficial owners imposed by the new Commercial Code, approved by Decree-Law no. 1/2022 of May 25 (article 99) and by the Law establishing the Legal Framework and Measures to Prevent and Combat Money Laundering and Terrorist Financing, Law no. 11/2022 of July 7 (article 18), the new Regulation on the Registration of Legal Entities, approved by Decree-Law no. 1/2024 of July 7 (article 18), has been introduced. The new Regulation on the Register of Legal Entities, approved by Decree-Law no. 1/2024, of March 8 (which repeals Decree no. 1/2006, of May 3, with the exception of Article 1 which creates the Register of Legal Entities) introduced the mechanism for declaring beneficial owners, which must be made within the following time limits:
– Up to 90 days after the application of this Regulation (i.e. until June 6, 2024), for companies that are already registered;
– In the consultative act (for new companies);
– Annually in the month of incorporation (update); and
– Up to 30 days after any change (update).
In the event of non-compliance with the above deadlines or the provision of false information, companies may be prevented from carrying out other procedures with the Legal Entities Registry Office and repeated non-compliance with the deadlines is subject to the imposition of a fine (not yet specified), without prejudice to criminal proceedings, where applicable.
Read more: Novo Código Comercial
