Curaçao – Recent developments regarding the UBO Registry

July 23, 2025

Introduction

In our previous article The Curaçao UBO Registry, we discussed the entry into force of the National Decree UBO Registration (“Decree”) as of  June 8, 2024, and the associated obligations for entities subject to administrative requirements in Curaçao. In the past weeks, several important developments have occurred, which we shall briefly outline in this follow-up article.

Deadline Extended up to and including September 30, 2025

The original deadline for existing entities to submit their Ultimate Beneficial Owner (“UBO”) information to the Chamber of Commerce and Industry was until July 1, 2025. However, the Minister of Finance (“Minister”) officially extended this deadline to up to and including September 30, 2025, as communicated in a formal notice published on June 27, 2025.

UBO Registration for Companies in Liquidation

An important point of attention for the UBO registration concerns companies currently in liquidation. The legislation does not explicitly exempt entities in liquidation from the UBO registration obligation, meaning that, in principle, these entities are still required to comply.

The Minister clarified in his notice that the UBO registration obligation only applies to entities that were in liquidation on the date the Decree entered into force (June 8, 2024) and entities that began the process of – liquidation within five years prior to that date, meaning as of June 8, 2019 onwards.

Entities that entered liquidation before June 8, 2019 are exempt from the UBO registration requirement, unless:

• The entity engages in decision-making that results in the revival of activities, or
• Exceptional circumstances indicate that registration is necessary to safeguard supervision or enforcement.

Entities within a Publicly Listed Group

Entities within the structure of a publicly listed group are, in principle, also required to register the entity in the UBO-registry. However, these entities are exempt from the obligation to submit information of the UBO (s) of the entity.

As no UBO is registered in these cases, the regular registration process does not apply. To accommodate such situations, the Chamber of Commerce introduced a separate procedure which must be completed using a specific form.

How we can be of service

HBN has a team specialized in providing assistance to determine the UBO and subsequent changes to this status. Our professionals are ready and happy to assist you, should any question arise regarding the submission of the required information or the timeframe in which certain information must be submitted.