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RCBE: what it is, who files, the deadline and the annual confirmation

After creating a company, there is an obligation to meet: declaring the beneficial owner in the Central Register of Beneficial Owners, known as the RCBE. This article explains what it is, who can file and the deadlines stated on the official page of the Portuguese registry (IRN).

Rules can change and each entity has its own situation. Always check the official service before acting.

What the RCBE is

According to the IRN, the Central Register of Beneficial Owners identifies all natural persons who, directly, indirectly or through third parties, hold ownership or effective control of legal entities. In other words, it shows who is ultimately behind the company.

When to file the initial declaration

According to the IRN, the initial declaration must be filed within 30 days. The count depends on the type of entity:

Entities subject to commercial registration

The period runs from the registration of the legal entity's incorporation.

Other entities

For entities not subject to commercial registration, it runs from the first entry in the Central File of Legal Persons. For entities that need not be entered there, it runs from the assignment of a tax number (NIF) by the Tax and Customs Authority.

If you are creating a company online, the service lets you fill in the beneficial owner during the process. If you do not, the IRN states that you have 30 days.

Who can file

The IRN states that the declaration can be filed by lawyers, notaries, solicitors and certified accountants, by managers or directors, by members of the board and by attorneys.

Note: a declaration registered by someone without standing is considered unvalidated and can be cancelled at any time by the IRN.

How to file

The declaration is filed online. You choose the authentication method (Cartão de Cidadão, Chave Móvel Digital or a legal professional's digital certificate), fill in the form and attach the required documents. Alternatively, you can book an in-person appointment at one of two locations indicated by the IRN.

Changes and annual confirmation

After the initial declaration, there are two upkeep duties:

Update when something changes

You must update the information whenever the declared data changes, within 30 days of the event that caused it.

Annual confirmation

Even if nothing has changed, you must confirm the information by 31 December each year. Confirmation is waived if the entity has already made an update earlier in the same calendar year. It can be submitted on the Portal das Finanças with the Simplified Business Information (IES), referring to the previous calendar year, or on the RCBE portal by submitting an update declaration.

The annual confirmation does not remove the need for updates required by later events.

How much it costs

According to the IRN, registering the beneficial owner is free of charge.

Key takeaways

  • The RCBE identifies the natural persons who effectively own or control an entity.
  • The initial declaration must be filed within 30 days.
  • Changes must be updated within 30 days, and there is an annual confirmation by 31 December.
  • Registration is free and can be done by lawyers, notaries, solicitors, certified accountants, managers or directors, board members and attorneys.

Frequently asked questions

Official sources

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