UBO-registratie: Laveren tussen transparantie en privacy

On Thursday 4 April 2019, the UBO registration implementation bill was submitted to the House of Representatives. In this contribution, the authors consider the fundamental question of whether the prescribed publicly accessible registration of UBO data passes the fundamental law test of the fundamental right to privacy, as enshrined in various human rights instruments. They also examine what room for manoeuvre the Dutch legislator still has in the concrete design of the registration to meet the criticisms expressed and what the follow-up steps might be.