Don't get lost in the beneficial owners register: a short guide to which form to use, when and why

Basic rule: electronic only

All submissions to the beneficial owners register are made exclusively through electronic forms of the Ministry of Justice. No other form of submission is permitted.

Forms are completed online and are typically:

• either sent to the registry court,
• or to the Ministry of Justice (for remote access requests).

Registration, change or deletion of a beneficial owner

Use the proposal form if you need to:

• register a beneficial owner,
• change already registered data,
• perform a deletion,
• or restrict access to data in the register (§ 32 ZESM).

How it works:

• you complete the form online,
• the output is a PDF document,
• you add attachments to the PDF and send it to the competent court.

This form is also used when you are only requesting restriction of access to data.

Automatic transcription of data (less manual work)

ZESM allows certain data to be automatically taken from other public registers. Separate forms are used for this.

1. Activation of automatic transcription

Used when you want to:

• only activate the automatic transcription regime (§ 41(2), § 61(2) ZESM),
• without dealing with specific persons.

The output is a PDF, which is sent to the court.

2. Registration of statutory body members as beneficial owners

Typically where:

• the beneficial owner is not identified otherwise,
• and all members of the statutory body are registered as beneficial owners (§ 5(1) ZESM).

Automatic transcription of future body members is activated at the same time. A separate form is used.

Remote access to the beneficial owners register

Standard request for remote access

Intended for:

• public authorities,
• and other entities defined by law (§ 16(2) ZESM).

The request:

• is submitted exclusively in electronic form,
• identifies the applicant and the specific persons who will access the register,
• is sent to the Ministry of Justice.

Automated remote access for obliged entities (AML)

For obliged entities under the AML Act (Act No. 253/2008 Coll.) there is a special, much simpler regime.

Characteristics:

• remote access under § 16(2)(o) ZESM,
• the form is completed after logging in via the data box system,
• access is set up immediately and automatically,
• specific authorised persons who will use the register are identified.

This regime is not available to everyone – conditions are set by the Ministry of Justice.

Why this matters from an AML perspective

For obliged entities:

• the beneficial owners register is a key source for identifying and checking clients,
• the wrong form = invalid submission,
• outdated or inaccessible data = risk of sanctions during inspection.

Properly set up access to the register means:

• less manual work,
• faster KYC/CDD processes,
• greater legal certainty in audit or FIU inspection.

Summary in one sentence

The beneficial owners register is not complicated – as long as you know which form to use, when and for what purpose.