The Dutch Ministry of Finance's policy rule, effective 1 June 2026, empowers penalties against trustees starting at EUR 2,750 for a first offence and doubling with each repeat violation within a five-year window, up to the statutory maximum of EUR 27,500.
The Netherlands Ministry of Finance has published a policy rule on 13 July 2026 outlining new administrative fine policies regarding the registration of ultimate beneficial owners (UBOs) for trusts and similar legal arrangements.
Effective from 1 June 2026, the regulation empowers the Ministry of Finance to penalise trustees who fail to provide accurate or timely information to the national UBO register.
The key details are as follows:
Fine structure and escalating penaltiesÂ
By law, the statutory maximum for these violations is tied to a fourth-category criminal fine, which currently stands at EUR 27,500. First offence costs 10% of the statutory max — EUR 2,750.
After that, the fine doesn’t just climb; it doubles each time: EUR 5,500 for a second violation, EUR 11,000 for a third, EUR 22,000 for a fourth, and EUR 27,500 (the full statutory ceiling) for a fifth or any repeat after that.
A violation only counts as “repeat” if it falls within five years of a prior fine or sanction becoming final and irrevocable — past that window, the count resets to zero.
Nuances and mitigating factorsÂ
Two practical rules on top of the fine structure.
- Multiple violations: If one act breaches several obligations at once, say failing to register a UBO while also failing to keep the existing record accurate, the trustee gets a single fine, not stacked penalties for each broken rule. The multiple breaches can still push that one fine higher, but they don’t multiply into separate charges.
- Mitigating circumstances: The Ministry may lower the fine based on specific circumstances, namely the financial capacity of the violator, the extent to which they cooperate during the investigation, and any corrective measures they implement to prevent the violation from continuing or recurring. However, the policy explicitly states that these factors can only be used to reduce the fine, and the burden of proof lies entirely on the violator to demonstrate why a reduction is justified.
