Declaration of real beneficiaries and submission of the environmental statement in 2021

1. Declaration of real beneficiaries in 2021

• Companies, associations and foundations constituted exclusively of natural persons are no longer required to submit a declaration of beneficial ownership. In all other cases, companies must still submit a declaration upon incorporation or whenever changes occur to the identification data of the real beneficiary.
• For companies established prior to 21 July 2019, the deadline for submissions of declarations of beneficial ownership has been extended due to the pandemic, with declarations now to be submitted within 90 days of the end of the state of alert, either online or through the post.
• According to GEO no. 191/2020, NGOs will need to declare their real beneficiaries every time the latter’s identification data changes.
• Real beneficiaries must also be declared during registration of trust deeds.
• The register of real beneficiaries will become operational as of 14 February 2021, and anyone will be able to request information from the Trade Register against payment of a given fee and without having to demonstrate a legitimate interest

2. Submission of the environmental statement 

The Environmental Fund Administration (AFM) recently announced that it will still be possible to submit declarations regarding financial obligations vis-à-vis the Environmental Fund in printed format up to and including March 2021.

As of April 2021, the said declarations are to be submitted exclusively by remote electronic means starting with the declaration for the March 2021 reporting period, with a submissions deadline of 26 April 2021.

The environmental statement can be submitted monthly, quarterly, half-yearly or annually, depending on the situation, in keeping with Order of the Ministry of Environment no. 591/2017.