UBO Filing Denmark: Beneficial Ownership Guide

What Is an Ultimate Beneficial Owner (UBO) in Denmark?

An Ultimate Beneficial Owner (UBO) is a natural person who directly or indirectly owns or controls more than 25% of a company’s shares or voting rights, or exercises control by other means such as board appointment rights, veto rights, or significant influence. The Danish term is reelle ejere. Ownership always traces to a natural person, never a legal entity, per Erhvervsstyrelsen.

This principle sits in Section 58a of the Danish Companies Act (selskabsloven). A holding company or trust can appear in the chain, but it can never be the registered UBO. You keep tracing until you reach a person.

What Is the 25% Ownership Threshold for UBOs in Denmark?

More than 25% of shares, voting rights, or control by other means makes someone a UBO in Denmark. The Danish Business Authority treats 25% as an indication of beneficial ownership, not a fixed legal cutoff, per Erhvervsstyrelsen. A person holding less, for example 15%, can still qualify if they exercise real control. The 25% figure is a trigger, not a safe harbor.

The same 25%-plus-one-share indicator appears in Directive (EU) 2015/849 (4AMLD), the EU source Denmark transposed.

How Does Indirect Beneficial Ownership Work in Denmark?

Companies must trace the full chain of ownership through every intervening entity, not just the direct parent, until a natural person is reached. The Danish Business Authority calls this unwinding the ownership chain (optrevle ejerkæden) using percent-of-percent calculations across each layer, per Erhvervsstyrelsen. You cannot stop at the first company you find.

Take a worked example. An individual owns 40% of Company A, and Company A owns 30% of Company B. That individual is likely a UBO of Company B through indirect ownership. An exempt or intermediate entity in the chain does not end the tracing duty. You still assess whether a natural person sits beneath it.

What Happens If No One Meets the 25% Threshold?

If no natural person qualifies as a UBO after exhausting all means of identification, the company registers its senior management (direktion) as beneficial owners instead. This fallback is written into Section 58a of the Companies Act and confirmed in Erhvervsstyrelsen guidance. The rule exists so the register is never left empty, which is a common first-time filing error that triggers enforcement.

Which Companies Must File UBO Information in Denmark?

Effectively all entities registered in the CVR must file UBO information. This covers limited companies, partnerships, cooperatives, commercial foundations, certain associations, and financial institutions, per Erhvervsstyrelsen. Ownership must always resolve to a natural person.

The entrepreneur company (IVS) is no longer a current entity. New IVS registrations ended 15 April 2019 and existing ones had to convert to an ApS or dissolve by 15 October 2021, per Retsinformation.

What Documents and Information Are Required for UBO Filing in Denmark?

Each UBO record needs a full legal name, identification number, nationality, country of residence, residential address, the nature and percentage of ownership or control, and the date ownership began. A CPR (Central Person Register) number only exists for people registered in Denmark. Foreign UBOs are identified by name, date of birth, nationality, and address, with ID and proof of address uploaded, per Erhvervsstyrelsen.

Danish UBO filing is a self-declaration system. There is no routine pre-verification. The Danish Business Authority runs risk-based controls and can demand supporting documentation, such as share registers and structure charts. Companies must keep that documentation for 5 years after the beneficial ownership period ends, per Companies Act §58a.

How Do You Register Beneficial Owners on Virk.dk (Step-by-Step)?

You register beneficial owners by logging in to Virk.dk with MitID Erhverv, opening “Ændre virksomhed”, going to “Ejerforhold” then “Reelle ejere”, entering each UBO’s details, uploading ID for foreign UBOs, and submitting. The record is then held in the CVR. The whole process runs online through the Danish Business Authority’s portal.

The numbered flow:

1. Prepare each UBO’s name, identifier, address, nationality, ownership percentage, and documents.
2. Log in to Virk.dk with MitID Erhverv.
3. Select “Ændre virksomhed” (change company).
4. Open “Ejerforhold” (ownership).
5. Choose “Reelle ejere” (beneficial owners).
6. Enter the details for each beneficial owner.
7. Upload passport or ID copies for any foreign UBO.
8. Submit the registration so it is recorded in the CVR.

What Are the UBO Filing Deadlines in Denmark?

New companies register UBOs as part of incorporation, and no CVR number is issued without them. Later changes must be registered as soon as possible (hurtigst muligt) after the company becomes aware of them, per Companies Act §58a. Companies must also review the registered information at least once a year.

What Are the Penalties for Not Filing UBO in Denmark?

Non-compliance carries fines under the Danish Companies Act, and the Danish Business Authority can send a company with no registered beneficial owners to the bankruptcy court for compulsory dissolution (tvangsopløsning). Company management has a duty to ensure the registration is made and kept current, per Companies Act §58a. A missing or empty beneficial ownership register is one of the clearest triggers for enforcement action.

Is the Danish UBO Register Public in 2026?

No. Since 1 September 2025, beneficial ownership data in the CVR is no longer publicly available. Access requires MitID authentication and a demonstrated legitimate interest. The restriction came in under Act No. 710 of 20 June 2025, following the CJEU judgment of 22 November 2022 (Joined Cases C-37/20 and C-601/20), which struck down unrestricted public access as a breach of privacy rights.

CJEU is the Court of Justice of the European Union. KYC below means Know Your Customer.

How Do Foreign-Owned Danish Companies Register Beneficial Owners?

Foreign-owned Danish companies use the same Virk.dk process. The difference is identification. Foreign UBOs without a CPR number are identified by full name, date of birth, nationality, and address, with a passport or ID copy and proof of address uploaded, per Erhvervsstyrelsen. A foreign representative needs MitID Erhverv access to file on the company’s behalf.

Tracing still runs up through foreign holding companies, funds, and trusts until a natural person is reached.

UBO Compliance Checklist for Danish Companies

• Identify every natural person through the full ownership chain.
• Apply the 25% test and the control-by-other-means test.
• Register senior management (direktion) if no UBO exists.
• File through Virk.dk with MitID Erhverv.
• Update the register as soon as you learn of a change.
• Review the registered information at least once a year.
• Retain supporting documentation for 5 years after ownership ends.

How We Help With UBO Filing in Denmark

Denmark’s UBO rules reward companies that keep ownership records clean and current. Commenda’s entity management platform tracks beneficial ownership records, filing deadlines, and ownership changes across jurisdictions, with automated alerts so Danish UBO updates never slip past the “as soon as possible” standard.

Pair it with the Commenda compliance calendar to see Danish and cross-border filing dates in one view. Book a demo to get a compliance review of your Danish entity’s UBO filings.