Effective 1 October 2024, the Register of Beneficial Owners was officially launched. The register is intended as a tool to combat money laundering, terrorist financing, and economic crime. It provides essential information about who ultimately owns and controls businesses.
Who is required to register, and what are their obligations?
The entities obligated to register include legal entities, associations, and other organizations, as well as trustees of foreign trusts and similar legal arrangements operating or registered in Norway, including on Jan Mayen and Svalbard.
Since 1 November 2021, these entities have been required to identify their beneficial owners and document the basis for such identification. This basis may include articles of incorporation, bylaws, shareholder registers, or agreements regarding the exercise of ownership rights and voting rights. Additionally, those required to register must collect personal data on the identified beneficial owners, including their ownership percentages and voting rights, and they must store this information. Should the registering entity conclude that no beneficial owners exist, or if they are unable to identify beneficial owners, these determinations must be justified, documented, and stored.
As of 1 October 2024, the information gathered about beneficial owners, along with the basis for their identification, must be submitted to the Register of Beneficial Owners. If it is determined that no beneficial owners exist, or if beneficial owners cannot be identified, this information must also be submitted. Registration is conducted through form RRH-0100 in Altinn. Entities are responsible for notifying beneficial owners of the registration of their information in the register.
Initial registration must occur within 14 days of the entity’s registration in a public register. Any updates to the register, such as the identification of new beneficial owners or changes in previously registered information, must be completed without delay and no later than 14 days after the change is identified.
Who qualifies as a beneficial owner?
Beneficial owners are individuals who ultimately own or control a legal entity, organization, or other association. Individuals who meet one or more of the following criteria are deemed beneficial owners. The registering entity is required to gather, store, and submit information about individuals who:
Directly or indirectly own more than 25% of the shares in the entity required to register
Directly or indirectly hold more than 25% of the voting rights in the entity required to register, in cases where voting rights distribution differs from shareholdings
Directly or indirectly have the authority to appoint or remove more than half of the members of the governing body of the entity or association, or
Exercise control over the entity in a manner not specified in the above three points
Beneficial ownership may be held indirectly by individuals who own or control 50% or more of other entities that, in turn, own or control more than 25% of the entity required to register, as outlined in points 1-4.
Consequences of non-compliance
Entities that fail to fulfill their obligation to register beneficial owners may be subject to enforcement actions and coercive fines. However, these measures will not be imposed until after 31 July 2025, providing entities sufficient time to identify and collect the required information.
In cases of deliberate non-compliance with the requirements to collect, store, or register information, additional penalties, including fines or imprisonment for up to one year, may be applied.