RCBE – Initial Declaration
The Initial Beneficial Owner Declaration is the first required filing with the RCBE and must be submitted within thirty days from:
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The incorporation of an entity subject to commercial registration (e.g.: companies and co-ops);
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Final registration with the Ficheiro Central de Pessoas Coletivas (Central Register of Legal Persons) for entities not subject to commercial registration (e.g. associations, foundations, unincorporated partnerships);
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Issuance of a NIPC by the Registo Nacional de Pessoas Coletivas (National Registry of Legal Persons), for foreign entities;
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Issuance of a NIF by the Portuguese Tax Authority for entities not subject to registration with the Ficheiro Central de Pessoas Coletivas (Central Register of Legal Persons).
Registration is required to ensure legal compliance from the outset of operations and corporate structure transparency.
Step-by-step
Step-by-step
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Collection and verification of the documentation required for the filing
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Filing of the initial declaration on the RCBE platform
01
Collection and verification of the documentation required for the filing
02
Filing of the initial declaration on the RCBE platform
FAQs
What is a beneficial owner?
Beneficial owners of an entity are the individuals who ultimately own or control the entity, or the individuals on whose behalf a transaction is carried out or a business conducted.
What are the legal criteria to determine beneficial ownership?
The law defines beneficial owners as:
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any person directly or indirectly holding shareholdings representing more than 25% of the share capital, voting rights or participation units;
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any person otherwise controlling the relevant entity (for instance, through agreements or special rights that grant it decision-making authority);
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if no one can be identified as described above, the person(s) in senior management (directors) shall be deemed to be the beneficial owners.
What happens if this declaration is not submitted?
Should the entity fail to submit the initial beneficial owner declaration, it will be in breach of its RCBE reporting obligations and barred from:
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Paying out profits or interim profits to shareholders.
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Executing or renewing contracts with the State (supplies, works, procurement of goods/services) and tendering for public utility concessions.
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Accessing public or European funds.
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Executing deeds for/sale and purchase of real property.