bank asks for the ultimate beneficial owners of our company how should I fill that in

UBO question comes from the bank's customer due diligence, not from the Business Register

The bank asks this based on its own customer due diligence obligation, which means the answer consists of two layers. Layer one is the formal registration: who is registered as UBO in the UBO register, which is part of the Business Register. Layer two is what the bank itself wants in addition: an explanation of the control structure, often with an organisational chart, and sometimes an explanation if the UBO holds a percentage just below or above the 25% threshold. Both layers must be consistent with each other — a bank that sees a discrepancy between the register and your own statement will almost always follow up with a question about it.

Therefore, do not only enter the names, but also the basis on which someone is a UBO: shareholding, voting rights, or de facto control through another route. If the structure runs through multiple intermediate holdings, a schematic representation is often faster to verify than continuous text. If you have already recorded this in the file, who are the ultimate beneficial owners of the company, then this is usually a matter of transferring it and checking the date of the last modification. With the same questionnaire, also pay attention to a separate question about politically exposed persons — whether a director or stakeholder is a PEP is often numbered separately, but belongs to the same customer due diligence block and is easily overlooked.

Legal basis: AML customer due diligence plus Business Register Act 2007

The bank's obligation to ask about UBOs follows from the Act on the Prevention of Money Laundering and Financing of Terrorism, which prescribes customer due diligence when entering into a business relationship; the formal registration of UBOs itself is governed by the Business Register Act 2007. These are two different regulations with two different objectives — one obliges the bank to ask questions, the other obliges the enterprise to register — and that explains why the answers must be consistent with each other but do not come from the same source.