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Beneficial ownership in Colombia: the DIAN RUB register, the 5 percent test and control filings

Last verified: 2026-10-26 · Status: Stable

Every Colombian company, branch or other permanent establishment, and many trusts and foreign holders, must report to DIAN's Registro Único de Beneficiarios Finales the individuals who own or benefit from 5 percent or more, or control the entity by other means, with the legal representative reported only as a fallback. New entities file within two months of RUT registration, check for changes on the first day of each quarter and update within a month; the register is confidential and errors are fined under the tax code. A foreign parent also registers its control of a Colombian company at the chamber of commerce within 30 days.

USD figures use the TRM (tasa representativa del mercado) of COP 3,158.43 per US dollar, valid 24 to 26 October 2026, from the official TRM series published by the Superintendencia Financiera on the national open data portal. Conversions are for orientation only.

Key facts

Ownership, voting or benefit threshold for a beneficial owner	5 %Estatuto Tributario art. 631-5 (Ley 2155 de 2021 art. 16), as of 2026-10-26 · in force
Beneficial ownership register	Registro Único de Beneficiarios Finales (RUB), part of the DIAN RUT, not public textEstatuto Tributario art. 631-6; Resolución 164 de 2021 art. 2 and art. 22, as of 2026-10-26 · in force
Deadline for a new entity's initial RUB filing after RUT registration	2 monthsDIAN Resolución 164 de 2021 art. 10 (Resolución 1240 de 2022), as of 2026-10-26 · in force
Quarterly dates to check whether RUB data changed	1 January, 1 April, 1 July, 1 October textDIAN Resolución 164 de 2021 art. 11, as of 2026-10-26 · in force
Deadline to update the RUB after a change found at a quarterly check	1 monthsDIAN Resolución 164 de 2021 art. 11, as of 2026-10-26 · in force
Minimum retention of supporting documents after a person stops being a beneficial owner	5 yearsDIAN Resolución 164 de 2021 art. 18 (Resolución 108 de 2023), as of 2026-10-26 · in force
Who is reported when no owner or controller is identified	The legal representative, unless another individual has greater management authority textEstatuto Tributario art. 631-5 lit. a num. 3, as of 2026-10-26 · in force
Deadline to register a control situation in the Registro Mercantil	30 daysLey 222 de 1995 art. 30, as of 2026-10-26 · in force
Unidad de Valor Tributario (UVT), 2026	52374 COPDIAN Resolución 238 de 2025, as of 2026-01-01 · in force
TRM used for USD conversions (valid 24 to 26 October 2026)	3158.43 COP per USDOfficial TRM series, Superintendencia Financiera de Colombia, as of 2026-10-24 · in force

The rule

1. Colombia's beneficial ownership register (Registro Único de Beneficiarios Finales, RUB) is part of the DIAN tax registry (RUT) and is the only channel to report beneficial owners. Those obliged to identify, obtain, keep, file and update the information are: Colombian companies and entities, with or without profit motive, including listed companies; permanent establishments, such as branches of foreign companies; trusts and other structures without legal personality created, administered or governed in Colombia or with a Colombian trustee; and foreign legal entities whose Colombian investment is not entirely held through reporting entities. Wholly publicly owned entities, embassies and accredited international organisations are exempt; mixed public and private companies are not.Estatuto Tributario art. 631-6 as amended by Ley 2155 de 2021 art. 17; DIAN Resolución 164 de 2021 (compiled in DIAN Resolución 227 de 2025), ET art. 631-6; Res. 164 art. 2, art. 4 (num. 4 as amended by Res. 37 de 2022) and art. 5, 2021-09-14 official text · verified 2026-10-26

2. A beneficial owner of a legal entity is (1) any individual who, alone or jointly, directly or indirectly holds 5 percent or more of the capital or voting rights, or benefits from 5 percent or more of the assets, returns or profits; and (2) any individual who, alone or jointly, controls the entity by other means. If no one is identified under those tests, the individual who is legal representative is reported, unless another individual has greater management or direction authority. The definition is read in line with the FATF recommendations and applies also as the tax concept of beneficial owner.Estatuto Tributario art. 631-5 as amended by Ley 2155 de 2021 art. 16; DIAN Resolución 164 de 2021 (compiled in DIAN Resolución 227 de 2025), ET art. 631-5 lit. a and par. 1 and 2; Res. 164 art. 6, 2021-09-14 official text · verified 2026-10-26

3. An individual acts jointly when acting with relatives up to the second degree of blood or marriage, or the first civil degree, whatever entities stand in between, or with third parties under an agreement. Indirect ownership covers holdings through one or more levels of ownership, nominees, representatives or intermediaries.
Example: Two siblings each hold 3 percent of a Colombian SAS through separate foreign companies. Acting jointly they reach 6 percent, so both are assessed as beneficial owners, but each is reported with an individual percentage of 3 percent (Res. 164 art. 8 par. 1).DIAN Resolución 164 de 2021 (compiled in DIAN Resolución 227 de 2025), Art. 1 num. 2, num. 7 and num. 8, 2021-12-27 official text · verified 2026-10-26

4. For trusts and similar structures without legal personality, the beneficial owners are the individuals who are settlors, trustees, members of the trust or financial committee, beneficiaries or conditional beneficiaries, and anyone else with effective control or a right to the assets or profits; where a legal entity holds one of those roles, its own beneficial owners are reported. A structure holding 5 percent or more of a company makes the structure's beneficial owners beneficial owners of the company. Where bearer shares or nominee shareholders exist in the chain, the filer reports the bearer share entity's name, tax ID and country, and the nominators behind the nominees.Estatuto Tributario art. 631-5 lit. b; DIAN Resolución 164 de 2021 (compiled in DIAN Resolución 227 de 2025), ET art. 631-5 lit. b; Res. 164 art. 6 par. 2 to 4 and art. 7, 2021-12-27 official text · verified 2026-10-26

5. For each beneficial owner the filer reports: type and number of ID and issuing country; tax ID or functional equivalent and country; full name; date and country of birth; nationality; country, state, city, address, postal code and contact details of residence; the criterion that makes the person a beneficial owner; the percentage of capital held and of returns or profits received, each individually and not jointly; and the dates on which the status began and, when relevant, ended. Colombian ID, tax ID, nationality and residence take priority over foreign ones.DIAN Resolución 164 de 2021 (compiled in DIAN Resolución 227 de 2025), Art. 8, 2021-12-27 official text · verified 2026-10-26

6. The filing is electronic through the DIAN RUB system, after adding the "Informante Beneficiarios Finales" responsibility to the RUT. Entities formed or obliged from 1 June 2023 file the initial report within two months after their RUT registration (or after inscription in the system for structures without legal personality, or after becoming obliged); entities that existed at 31 May 2023 had until 31 July 2023. Information is given as of the filing date.
Cost to do it: DIAN charges nothing to file.DIAN Resolución 164 de 2021, art. 10 as amended by Resolución 1240 de 2022, Art. 9 and art. 10, 2021-12-27 official text · verified 2026-10-26

7. The filer must check on the first day of January, April, July and October whether anything changed and, if so, update the RUB within the following month; if nothing changed, no filing is needed. When the entity is liquidated, its beneficial owners are unlinked automatically once its RUT is cancelled.
Example: A foreign parent sells 30 percent of its shares to a new investor on 20 February. At the 1 April check the SAS sees the change and updates the RUB by 30 April.DIAN Resolución 164 de 2021 (compiled in DIAN Resolución 227 de 2025), Art. 11, 2021-12-27 official text · verified 2026-10-26

8. Obliged entities must carry out due diligence to identify their beneficial owners, and shareholders, partners and other entities in the chain must provide the information requested. Supporting documents and the due diligence must be kept while the person remains a beneficial owner and for at least five years after the person loses that status. The information in the RUB is confidential under the Estatuto Tributario.DIAN Resolución 164 de 2021, art. 18 as amended by Resolución 108 de 2023, Art. 17, art. 18 and art. 22, 2021-12-27 official text · verified 2026-10-26

9. Failing to provide beneficial ownership information, providing it wrongly or incompletely, or not updating it is sanctioned under art. 658-3 of the Estatuto Tributario, whose fines include one UVT per day of delay in updating registry information and 100 UVT for false, incomplete or wrong data. Abusive use of the filing rules is treated as a tax benefit obtained for the purpose of the abuse rules.
Cost to do it: At the 2026 UVT of COP 52,374: COP 52,374 (US$16.58) per day of late updating; COP 5,237,400 (US$1,658.23) for false, incomplete or wrong data.Estatuto Tributario art. 631-6 and art. 658-3; DIAN Resolución 164 de 2021 (compiled in DIAN Resolución 227 de 2025), ET art. 631-6 and art. 658-3 num. 3 and num. 4; Res. 164 art. 20 and art. 21, 2021-09-14 official text · verified 2026-10-26

10. Separately from the tax register, when a company is controlled (for example a foreign parent owning more than 50 percent), the controlling party registers the control situation in the Registro Mercantil of each controlled company within 30 days, and the chamber shows the parent or subsidiary status and any business group on the certificate of existence and legal representation; later changes must also be registered.
Cost to do it: Inscription of the control document: 6 UVB, COP 73,000 (US$23.11) in 2026.Ley 222 de 1995; Código de Comercio art. 261 as replaced by Ley 222 art. 27, Ley 222 art. 30 and par. 1 and 2, 1995-12-20 official text · verified 2026-10-26

Structure	Reported as beneficial owners
SAS 100% owned by a foreign company owned 60/40 by two individuals	Both individuals (60% and 40% indirectly)
SAS owned by a listed foreign group with no individual at 5%	Individuals controlling by other means; otherwise the legal representative or a person with greater management authority
SAS 10% held through a foreign trust	The trust's settlors, trustees, committee members, beneficiaries and controllers
Shares held by a nominee	The nominator behind the nominee
Chain with bearer shares	The bearer share entity's name, tax ID and country, plus identifiable individuals

Who is a beneficial owner in common foreign investor structures (Estatuto Tributario art. 631-5; Resolución 164 de 2021 art. 6 and 7).

Worked example

A Colombian SAS is owned 100 percent by a Delaware company, which is owned 70 percent by its individual founder and 30 percent by a foreign discretionary trust whose beneficiaries are the founder's two children.
The SAS adds the beneficial owner responsibility to its RUT and, within two months of RUT registration, reports the founder (70 percent indirect, Estatuto Tributario art. 631-5 lit. a) and, because the trust holds 5 percent or more, the trust's settlor, trustee (or the individuals behind a corporate trustee), any committee members and the two children as beneficiaries (Resolución 164 art. 6 par. 4 and art. 7), each with individual percentages (art. 8 par. 1).
The Delaware parent also registers its control situation at the chamber within 30 days (Ley 222 de 1995 art. 30), at a cost of COP 73,000 (US$23.11).
When the trustee adds a new beneficiary in May, the change is caught at the 1 July check and the RUB is updated by 31 July (Resolución 164 art. 11).

Step by step

1. Map the full ownership and control chain up to individuals, including trusts, nominees and bearer shares.
2. Apply the 5 percent tests (capital, votes, benefit), the control test and, only if both fail, the legal representative fallback.
3. Collect the art. 8 data and supporting documents from each beneficial owner and intermediate entity.
4. Add the "Informante Beneficiarios Finales" responsibility to the RUT and file electronically within two months of RUT registration.
5. Diarise the quarterly checks on 1 January, April, July and October and keep the file for five years after any person drops out.
6. Register the foreign parent's control situation at the chamber within 30 days, and register later changes.

Common traps

Reporting only the direct corporate shareholder. The register asks for individuals at the top of the chain (Estatuto Tributario art. 631-5).
Adding up family holdings wrongly. Relatives up to the second degree act jointly for the 5 percent test, but percentages are reported individually (Resolución 164 art. 1 num. 2 and art. 8 par. 1).
Defaulting to the legal representative when an individual controls by other means (art. 631-5 lit. a num. 2).
Forgetting the quarterly check after a share sale or a trust change; late updates are fined daily (Estatuto Tributario art. 658-3).
Destroying records when a beneficial owner exits; keep them for five years (Resolución 164 art. 18).
Treating the chamber control filing as a substitute for the RUB, or the other way round; both are required (Ley 222 de 1995 art. 30; Resolución 164 art. 10).

Sources

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