The Belgian register of shares: who keeps it, who can see it, and how to find a company's shareholders
Tips
The short answer
The register of shares (aandelenregister in Dutch, registre des actions in French) is the list a Belgian company keeps of who holds its registered shares. Every BV and CV must keep one, because their shares are always registered. An NV keeps one for its registered shares; dematerialised NV shares sit on securities accounts instead. It records each shareholder, their shares, their rights and every transfer, and a transfer only counts against the company and third parties once it is entered. It can be a paper book or, if the board decides, an electronic register such as eStox. It is not public: the Code of Companies and Associations gives shareholders the right to see it, not outsiders. From outside, you work with the filed annual accounts, the Official Gazette and, if you qualify, the UBO register.
The rules below come from the Code of Companies and Associations on Justel, the National Bank's filing models and eStox's own site, read on 1 October 2026. This is general information, not legal advice.
Which companies must keep a register of shares
The obligation follows the form of the shares, and the form follows the legal form of the company.
Legal form | Form of the shares | Register of shares |
|---|---|---|
BV / SRL | Always registered (art. 5:18), except a listed BV whose statutes allow dematerialised shares | Mandatory, kept at the registered office (art. 5:24 and 5:25) |
CV / SC | Only registered shares with voting rights (art. 6:19) | Mandatory (art. 6:24 and 6:25) |
NV / SA | Registered or dematerialised (art. 7:22); registered until fully paid up (art. 7:47) | Mandatory for the registered shares (art. 7:28 and 7:29); dematerialised shares are transferred from one securities account to another (art. 7:75) |
Bearer shares no longer exist for these companies. A separate register is kept for each other category of registered securities, such as bonds.
What the register must contain
The content is the same for the BV (art. 5:25), the CV (art. 6:25) and the NV (art. 7:29):
The total number of shares issued and, where relevant, the number per class.
For each shareholder: name and domicile for a natural person, name and registered office for a legal entity.
The number and class of shares each shareholder holds.
The payments made on each share.
Transfer restrictions in the statutes and, if a party asks, those from agreements or the terms of issue.
Transfers and transmissions of shares, with their date.
The voting and profit rights attached to each share, and the share in the liquidation surplus if it differs from the profit rights.
Two rules make the register more than paperwork. Whoever is entered as holder is presumed to be the holder until the contrary is proven (art. 5:29 for the BV). And a transfer of registered shares can only be invoked against the company and third parties through a declaration of transfer entered in the register, dated and signed by transferor and transferee (art. 5:61 for the BV, 7:74 for the NV). If the register and the statutes contradict each other, the statutes prevail.
Paper or electronic register
The classic register is a bound book kept at the registered office. The Code lets the board decide to keep it in electronic form instead, and lets the King set conditions for electronic registers. A declaration of transfer in an electronic register can be signed with an electronic signature as defined in the EU eIDAS regulation, wording in force since 25 July 2021.
The best known electronic option is eStox, which presents itself as offered by notaries, accountants and tax advisers. According to its site, only those professionals can create and update a register, directors and security holders log in with eID or itsme to consult it and download a copy, and the data can be sent to the UBO register of FPS Finance. eStox does not publish a price; the notary, accountant or tax adviser quotes one. The Code itself does not prescribe a provider.
Who can see it
The Code gives a consultation right to the holders: "notwithstanding any contrary provision", security holders can inspect the full register for their category of securities (art. 5:24, 6:24 and 7:28). It gives no such right to the public, and eStox, for example, is open only to directors and security holders. A supplier, competitor or journalist cannot ask to see the register of a company they have no stake in. A buyer or lender can ask for it as part of due diligence on a Belgian company, and the company decides whether to share it.
Share register, UBO register and annual accounts compared
Source | What it shows about ownership | Who can see it | Limit |
|---|---|---|---|
Register of shares | Every registered shareholder, their shares and every transfer | Shareholders, for their category; the company's directors | Not public |
UBO register (FPS Finance) | The natural persons at the end of the ownership or control chain | Authorities, obliged entities, and since 17 February 2023 members of the public who meet one of three conditions | Restricted access |
Annual accounts, full and abbreviated models | Shareholder structure at year end, participations of 10% or more, the parent company that consolidates | Anyone, free, at the National Bank | A year-end snapshot, based on notifications received |
Annual accounts, micro model | Participations of 10% or more | Anyone, free | No shareholder structure section |
Official Gazette | Founders and their contributions, capital changes, mergers | Anyone, free | Later share sales between shareholders are not published |
The shareholder structure section deserves a warning. In the full model (section VOL-kap 6.7.2) and the abbreviated model (VKT-kap 8), the company lists its shareholders "as it appears from the notifications" it received under article 7:225 of the Code, the transparency law of 2 May 2007 or a rule for multilateral trading facilities. How complete it is varies from filing to filing, so an empty section does not prove there are no significant shareholders.
How to find out who owns a Belgian company from outside
Start with the legal form in the KBO. A BV or CV always has a register of shares; an NV may have dematerialised shares that appear in no register the company keeps.
Open the latest annual accounts. Look them up for free at the National Bank and check which model was filed. In a full or abbreviated model, read the shareholder structure, the list of companies in which the company holds at least 10% (VOL-kap 6.5.1, VKT-kap 7.1, also MIC-kap 7.1 in the micro model) and the statement on consolidated accounts (VOL-kap 6.18, VKT-kap 6.7), which names the parent company if the company is a subsidiary.
Follow the parent. Open the parent's own accounts. A parent that controls subsidiaries must draw up consolidated accounts (art. 3:23), unless it heads a small group (art. 3:25) or is itself consolidated higher up (art. 3:26).
Read the Official Gazette. The extract of the incorporation deed names the founders and their contributions (art. 2:8). Capital increases and restructurings are published too. Searching the Gazette and tracking mergers and demergers show where ownership changed hands through a formal operation.
Check the UBO register if you qualify. The Belgian UBO register explains the three conditions for public access.
Ask. In a sale, investment or large contract, ask for an extract of the register of shares signed by the board.
Done by hand, this means one PDF per legal entity and a new search for every parent. Bizzy's legal entity record has an Ownership tab with two views: a group structure tree that shows the parent, the ownership percentage and the country for each entity, with subsidiaries nested beneath it, foreign ones included, and a shareholders view. It is ownership rebuilt from public filings, not a copy of the share register or the UBO register, so for a transaction you still ask the company for its register. Plans start free.
Frequently asked questions
Is the Belgian register of shares public? No. The Code of Companies and Associations lets shareholders inspect the full register for their category of shares, but gives the public no right to consult it.
Is an electronic register of shares mandatory? No. The board can decide to keep the register electronically, for example in eStox, but a paper register kept at the registered office remains valid.
Where can I see who the shareholders of a Belgian company are for free? In the shareholder structure section of the annual accounts filed at the National Bank, if the company files a full or abbreviated model, and in the Official Gazette for founders and capital changes. The micro model has no shareholder structure section.
What is the difference between the share register and the UBO register? The share register lists every direct shareholder, which can be another company, and is kept by the company itself. The UBO register, kept by FPS Finance, lists the natural persons who ultimately own or control the company, typically through more than 25%.
Photo: Saint Michael's bridge in Ghent at blue hour, Edison McCullen, CC BY-SA 4.0, via Wikimedia Commons