In particular, Article 17 of the Law on State Registration is supplemented by new rules and obliges the applicant to submit to the State Registrar the following documents for certain registration actions to establish information about the final beneficial owners (FBO):

- ownership structure by form and content, determined in accordance with the law;

- extract, extract or other document from the commercial, banking, court register, etc., which confirms the registration of a non-resident legal entity in the country of its location, - if the legal entity is a non-resident legal entity;

- a notarized copy of a document certifying the person who is a corporate legal entity - for a non-resident individual and, if such a document is drawn up without the use of the Unified State Demographic Register, - for a resident individual.

It should be noted that in accordance with part two of Article 17 of the Law on State Registration (in the wording of Law No. 361-IX) legal entities are obliged to keep the information on the KBV and the ownership structure up-to-date, to update it and to notify the state registrar of changes within 30 working days on the day of their occurrence, and submit to the state registrar documents confirming these changes. If there are no changes in the structure of ownership and information about the legal entity's FBO, legal entities are obliged to notify the state registrar of the absence of such changes during the state registration of any changes to the information about the legal entity contained in the Unified State Register of Legal Entities, Individual Entrepreneurs and public entities (Unified State Register).

In order to establish a common practice for the implementation of the changes, the Ministry of Justice prepared a letter dated April 23, 2020, No. 3887 / 8.4.4 / 32-20 "On submission of information about the final beneficial owners".

In particular, the Ministry of Justice has clarified that the updated application forms are currently in the process of being approved and are due to be implemented in the near future. Such forms will contain fields for submitting information on the CVD in accordance with the accepted amendments to the Registration Law. In particular, there will be fields to indicate that the FBO information contained in the Unified State Register is up-to-date or needs to be modified.

Thus, if the applicant indicates in the application that the FBO information is up-to-date, the registration law does not provide for the submission of documents that are provided for establishing the FBO information.

The ministry also noted that the list of economic entities for which the FBO information is not entered in the Unified State Register has been changed, and the provision on non-submission of FBO information in the case that the founders of the legal entity are exclusively natural persons who are the FBO of such legal entity , excluded from the Registration Act.

Regarding the actions of the state registrar in the case of submission of documents on KBV with violation of the established term, the Ministry of Justice stated that to fill the Unified State Register with reliable information about the FBO of the legal entity in case of submission of such documents with violation of the statutory term in the absence of other grounds for suspension and refusal state registration The state registrar conducts the relevant state registration and reports the specified term violation.

Regarding the date from which the legal entity has the obligation to submit to the State Registrar documents for establishing information about the CSR, part four of Section X "Final and Transitional Provisions" of Law No. 361-IX specifies that legal entities registered before this Law enters into force, submit to the State Registrar information about the FBO within the scope specified by this Law and the ownership structure within three months from the date of entry into force of the normative legal act, which will approve the form and content of the ownership structure.

Therefore, all legal entities, for which the Unified State Register must contain information about FBO and which have been registered before the entry into force of the legal act, which will approve the form and content of the ownership structure, must, from the date of entry into force of such act, submit to the state registrar documents for updating in the Unified State Register of FBO Information.

Submission of such documents may be carried out both in the package of documents submitted in accordance with part four of Article 17 of the Law on Registration, as well as in the course of other registration actions, the commission of which provides for the submission of documents for establishing information about FBO.

However, the administrative fee is charged only if such documents are submitted in accordance with part four of Article 17 of the Law on Registration.

Given the above, by the date of entry into force of a legal act that will approve the form and content of the ownership structure of a legal entity, submission to the state registrar of documents to establish information about the FBO for registration activities is not required. However, please note that the relevant application will be completed in accordance with the prescribed form.

As of today, the form and content of the ownership structure are not confirmed by the Ministry of Finances.