On October 27, 2025, Decree-Law No. 115/2025 was published, amending the legal regime of the Central Register of Beneficial Ownership (Ultimate Beneficial Owner_UBO), approved by Law No. 89/2017, of August 21. The law, which comes into force on November 1, 2025, aims to transpose Article 74 of Directive (EU) 2024/1640, of May 31, which amends Articles 30 and 31 of Directive (EU) 2015/849, strengthening mechanisms to prevent the use of the financial system for money laundering or terrorist financing.
This change follows the judgment of the Court of Justice of the European Union in joined cases C-37/20 and C-601/20, WM and Sovim SA/Luxembourg Business Registers, which declared that generalized access to information on beneficial owners is incompatible with the right to personal data protection. With this reform, the Portuguese legislator seeks to reconcile the requirement for corporate transparency with the safeguarding of the fundamental right to privacy.
The law also revises Article 4 of the RCBE legal regime, expanding the set of entities excluded from the registration obligation and expressly including undivided estates, which are no longer required to identify their beneficial owner.
The Corporate Law Department of Belzuz Abogados, S.L.P. Law Firm in Portugal has a team of experienced lawyers to provide the necessary legal advice for compliance with UBO obligations and the protection of the personal data of beneficial owners.