If your German company has legal entity shareholders—such as another GmbH, AG, or partnership—Qonto must identify the ultimate beneficial owners (UBOs) behind those entities. This requirement follows German financial regulations and BaFin's (Bundesanstalt für Finanzdienstleistungsaufsicht) guidelines on correctly calculating UBOs in single-tier and multi-tier corporate structures.
We request this information during account opening and periodically as part of ongoing compliance reviews. You'll receive a request via email and in-app notification when we need documentation about your shareholder legal entities.
This process is mandatory—without the required documentation, we cannot complete your onboarding or maintain your account in good standing.
What documents do I need to provide about my shareholder legal entities?
To identify the UBOs behind your shareholder legal entities, please provide one of the following documents:
- Gesellschafterliste (Shareholder list): This is our preferred document as it clearly shows the ownership structure of the legal entity shareholder.
- Satzung (Bylaws/Articles of association): You can provide this as an alternative if the shareholder list is not available.
Both documents must be:
- In PDF format
- Notarized (standard practice for these German corporate documents)
- Provided in German.
In some cases, we may also request:
- Commercial extract (Handelsregisterauszug) of the shareholder legal entity
- Proof of identity (POI) for the ultimate beneficial owners (natural persons with ownership or voting rights).
☝️ If you understand your corporate structure well, you are welcome to provide UBO diagrams or any other helpful documentation that illustrates the ownership chain. This can speed up the review process.
How do I submit these documents?
You can submit the required documents through two methods:
- Via the Qonto app (💻 web or 📱 mobile): A banner will appear on your main view with instructions about the compliance request. Click on the banner and follow the instructions to upload your documents directly.
- Via email reply: Simply reply to the compliance request email we sent you and attach the required documents.
After you submit the documents, our compliance team will review them to verify the UBO structure.
If we need additional clarification about the ownership chain or require supplementary documentation, we'll contact you with specific instructions.
What happens if I don't provide these documents?
Providing documentation about your shareholder legal entities is mandatory for German corporations and partnerships with legal entity shareholders.
During onboarding:
If you don't provide the required documents, we cannot complete your account opening process. Your onboarding will remain on hold until you submit the necessary documentation.
During periodic reviews:
If you don't respond to our compliance request during an ongoing review, your account may face restrictions until you provide the required information.
⚠️ This requirement applies to all Qonto plans and cannot be waived—it's mandated by German financial regulations (BaFin).
We only request this information when we cannot gather the necessary documentation about your shareholder legal entities through our own resources.
💡 Note: For more information about what is required to open an account, see here: Which documents do I need to open an account in Germany?