Countries › Uruguay › Guide › 4. Entities and setup › Beneficial ownership and shareholder reporting to the BCU in Uruguay

Beneficial ownership and shareholder reporting to the BCU in Uruguay

Last verified: 2026-10-27 · Status: Stable

Uruguayan entities, and foreign entities with a permanent establishment, effective management or more than UI 2.5 million of assets in Uruguay, must identify every individual who holds 15 percent or more of capital or votes, or exercises final control, and file a sworn statement with the register kept by the Banco Central del Uruguay (Ley Nº 19.484). Issuers of registered or book entry shares, such as S.A. and SAS, also report every shareholder and percentage. New entities file within 45 days of formalization (90 when non residents are involved), changes are reported in the same terms, and missing filings bring fines of up to 100 times the maximum Tax Code fine, a ban on dividends to unidentified holders, suspension of the tax compliance certificate and a block on registry filings.

USD figures use UYU 40.214 per US dollar, the Banco Central del Uruguay (BCU) quotation for DLS. USA BILLETE on 26 October 2026. Amounts set in Unidades Indexadas (UI) use UYU 6.6792 per UI (BCU, 27 October 2026); amounts set in Unidades Reajustables (UR) use UYU 1,940.77, the September 2026 UR (Decreto 229/026, IMPO UR table, the latest month published on the verification date). Conversions are for orientation only.

Key facts

Beneficial owner threshold (capital or votes)	15 %Ley Nº 19.484 art. 22, as of 2026-10-27 · in force
Beneficial owner register keeper	Banco Central del Uruguay Ley Nº 19.484 art. 27, as of 2026-10-27 · in force
New entities: deadline to file the beneficial owner statement (resident owners)	45 daysDecreto Nº 166/017 art. 25, as of 2026-10-27 · in force
New entities: deadline when holders or owners are non resident	90 daysDecreto Nº 166/017 art. 25, as of 2026-10-27 · in force
Deadline to report beneficial ownership changes (resident owners)	45 daysLey Nº 19.484 art. 30, as of 2026-10-27 · in force
Deadline to report beneficial ownership changes (non resident owners or chain members)	90 daysLey Nº 19.484 art. 30, as of 2026-10-27 · in force
Minimum retention of identification records after the relationship ends	5 yearsDecreto Nº 166/017 art. 14, as of 2026-10-27 · in force
Non resident entities: Uruguayan assets above which the duty applies	2500000 UILey Nº 19.484 art. 24, as of 2026-10-27 · in force
Maximum fine for identification or filing failures (multiple of Tax Code max fine)	100 timesLey Nº 19.484 art. 32, as of 2026-10-27 · in force
Maximum fine for identification or filing failures, 2026	1322000 UYULey Nº 19.484 art. 32; Decreto Nº 344/025, as of 2026-10-27 · in force
Beneficial owner register open to the public	No Ley Nº 19.484 art. 39, as of 2026-10-27 · in force
Maximum contravention fine under Tax Code art. 95 for 2026	13220 UYUDecreto Nº 344/025 art. 1, as of 2026-10-27 · in force
UYU per US dollar used for conversions (BCU, 26 Oct 2026)	40.214 UYUBCU quotation DLS. USA BILLETE, as of 2026-10-27 · in force
Unidad Indexada value used for conversions (BCU, 27 Oct 2026)	6.6792 UYUBCU quotation UNIDAD INDEXADA, as of 2026-10-27 · in force

The rule

1. A beneficial owner is any individual who directly or indirectly holds at least 15 percent of the capital or its equivalent, or of the voting rights, or who by other means exercises final control of an entity, whether a company, trust, investment fund or other structure; control may be direct, through a chain of ownership or by any other means. For trusts, the individuals meeting that test among settlors, trustees and beneficiaries must be identified.
Cost to do it: No cost; definition.
Example: A Uruguayan SAS owned by a foreign holding in which one founder has 60 percent and four investors 10 percent each: only the founder is a beneficial owner by ownership, unless another person controls by other means. / No cost.Ley Nº 19.484 (Fiscal Transparency Law), Art. 22, 2017-01-05 official text · verified 2026-10-27

2. Resident entities must identify their beneficial owners unequivocally with supporting documents. Non resident entities have the same duty when they act through a permanent establishment in Uruguay, have their effective management seat in Uruguay, or hold Uruguayan assets above UI 2,500,000 valued under IRAE rules; foreign trusts and funds with a Uruguay resident trustee or manager are also covered. The decree lists S.A., limited partnerships by shares, agrarian companies, trusts and funds, SRL, de facto and general partnerships, cooperatives, foundations, economic interest groups and civil associations, and non resident entities caught by the law must register with the DGI.
Cost to do it: UI 2,500,000 is about UYU 16,698,000 (US$415,229) at the 27 October 2026 UI; for this test the decree values assets at the UI of 31 December of the prior year.
Example: A foreign company owning a Montevideo office worth UYU 20,000,000 and no other activity is obliged because its Uruguayan assets exceed UI 2.5 million. / About US$415,229 of Uruguayan assets triggers the duty for a non resident.Ley Nº 19.484; Decreto Nº 166/017, Ley 19.484 art. 23 and art. 24; Decreto 166/017 art. 3, 2017-06-26 official text · verified 2026-10-27

3. Issuers of registered or book entry shares or participations (S.A., limited partnerships by shares, agrarian associations and any entity able to issue registered participations) must also report to the BCU the identity of each holder and its percentage of capital; the SAS law applies the same rules to SAS. Holders of bearer shares must give the issuer their identification and holdings for the BCU register under Ley 18.930.
Cost to do it: No filing fee.
Example: An S.A. with 12 shareholders reports all 12 and their percentages, plus the individuals at 15 percent or more behind any corporate holder. / No cost.Ley Nº 19.484, art. 25 as worded by Ley Nº 19.924; Ley Nº 19.820; Ley Nº 18.930, Ley 19.484 art. 25; Ley 19.820 art. 16; Ley 18.930 art. 1, 2020-12-18 official text · verified 2026-10-27

4. The sworn statement lists the beneficial owners identified with their percentages, the share held by persons who do not meet the test, the share whose beneficial owner is unknown, and who exercises final control, with the full ownership chain when control is indirect. For each owner it includes name, marital status and property regime, addresses, nationality and identity or tax numbers, and whether the owner is resident; for each chain entity its name, place and date of formation, addresses and tax number. Entities keep the supporting documents like mandatory corporate books for at least 5 years after the owner's relationship ends.
Cost to do it: Internal compliance cost to gather chain documents; no fee.
Example: A three tier structure (Uruguayan SAS, Spanish holding, founder) must show both entities and the founder in the statement. / No fee.Ley Nº 19.484; Decreto Nº 166/017, art. 14 as worded by Decreto Nº 256/019, Ley 19.484 art. 26 and art. 29; Decreto 166/017 art. 5 and art. 14, 2019-09-02 official text · verified 2026-10-27

5. Entities formed or becoming obliged file the statement within 45 days of their effective formalization, or 90 days when holders, chain members or beneficial owners are non resident. Any later change, including in the ownership chain, is reported by a new sworn statement within 45 days, or 90 days for non residents, counted from the corporate act or resolution when percentages change through a bylaw change or capital increase; changes in addresses, marital status or representatives' roles can be reported within 90 days after the end of the calendar year. After a death, terms run from the declaration of heirs.
Cost to do it: No fee; late filing triggers graded fines (next rule).
Example: An SAS registered on 2 November 2026 with a foreign parent must file by 31 January 2027 (90 days); a later share transfer between resident individuals is reported within 45 days. / No fee.Ley Nº 19.484, art. 30 as worded by Ley Nº 19.924; Decreto Nº 166/017, art. 11 and art. 25 as worded by Decreto Nº 272/022, Ley 19.484 art. 30; Decreto 166/017 art. 11, art. 11 BIS and art. 25, 2022-08-30 official text · verified 2026-10-27

6. Failure to identify owners or holders, to keep the documents, or to file the sworn statement is fined up to 100 times the maximum contravention fine of art. 95 of the Tax Code, and the entity's legal and voluntary representatives are personally exposed; hiding the owner through inappropriate legal forms is fined up to 1,000 times. Fines are graded by size (small and medium entities have assets up to UI 7,500,000 and income up to UI 24,000,000), by delay (under 6 months, 6 months to 2 years, 2 years or more) and by the unidentified share: from 2 to 50 times for small and medium entities and from 3 to 100 times for large ones; for shareholder data the scale runs from 5 to 40 times and 10 to 100 times. Dividends, redemptions, withdrawals and liquidation proceeds cannot be paid to unidentified holders on pain of a fine up to the amount paid, the tax compliance certificate is suspended and the entity cannot register acts at the national registries.
Cost to do it: Maximum contravention fine for 2026: UYU 13,220. Ceilings: 100 times UYU 1,322,000 (US$32,874); 1,000 times UYU 13,220,000 (US$328,741). Lowest step: 2 times UYU 26,440 (US$657).
Example: A small SAS that files 4 months late with its whole 100 percent ownership unknown to the register faces up to 5 times the maximum fine, UYU 66,100. / About US$1,644 for that case; up to US$32,874 for large entities two years or more late.Ley Nº 19.484; Decreto Nº 166/017, art. 21 as worded by Decreto Nº 272/022; Decreto Nº 344/025, Ley 19.484 art. 32 to 37; Decreto 166/017 art. 21; Decreto 344/025 art. 1, 2025-12-30 official text · verified 2026-10-27

7. The register information is secret. Access is limited to the DGI once a formal audit of specific taxpayers has started or for a treaty based exchange of information request, the anti money laundering secretariat (SENACLAFT) and the BCU financial intelligence unit, criminal courts or courts in alimony matters, the Junta de Transparencia y Ética Pública in its cases, and the National Customs Directorate for audits or customs offence prevention; otherwise only with written consent of the persons registered. Reporting entities under the AML law must ask clients for this information in their due diligence. Exempt from identification: listed entities and their subsidiaries, supervised foreign funds and trusts as regulated, condominiums and marital property, and from filing: partnership type companies wholly owned by individuals who are their beneficial owners.
Cost to do it: No cost.
Example: A bank opening an account for a new SAS will ask for the BCU filing receipt as part of its due diligence. / No cost.Ley Nº 19.484, art. 39 as amended by Ley Nº 19.535, Ley Nº 20.018 and Ley Nº 20.446; art. 31 as worded by Ley Nº 19.924, Art. 31, art. 38, art. 39 and art. 40, 2025-12-16 official text · verified 2026-10-27 · changed: Ley Nº 20.446 of 16 December 2025, art. 200, added the National Customs Directorate to the bodies that may access the register.

Entity size and unknown share	Under 6 months	6 months to 2 years	2 years or more
Small or medium, under 20% unknown	2x (UYU 26,440)	5x (UYU 66,100)	20x (UYU 264,400)
Small or medium, 20% to 50%	3x (UYU 39,660)	10x (UYU 132,200)	35x (UYU 462,700)
Small or medium, over 50%	5x (UYU 66,100)	15x (UYU 198,300)	50x (UYU 661,000)
Large, under 20% unknown	3x (UYU 39,660)	10x (UYU 132,200)	35x (UYU 462,700)
Large, 20% to 50%	5x (UYU 66,100)	15x (UYU 198,300)	50x (UYU 661,000)
Large, over 50%	10x (UYU 132,200)	20x (UYU 264,400)	100x (UYU 1,322,000)

Fine scale for not identifying or reporting beneficial owners, in multiples of the maximum Tax Code fine (UYU 13,220 in 2026), Decreto Nº 166/017 art. 21

Worked example

A large entity (assets above UI 7.5 million, about UYU 50.1 million or US$1.25 million, or income above UI 24 million, about UYU 160.3 million or US$3.99 million) that never reported a controlling foreign owner for over two years faces up to UYU 1,322,000 (US$32,874), plus the dividend ban and a suspended tax certificate.
Smallest step: a small SAS under 6 months late with less than 20 percent unknown, up to UYU 26,440 (US$657).

Step by step

1. Map the full ownership chain up to individuals and identify those at 15 percent or more of capital or votes, or with control by other means.
2. Gather identification documents for each owner and each chain entity and file them with the corporate books.
3. File the sworn statement with the BCU register within 45 days of formalization, or 90 days if any holder, chain member or owner is non resident; S.A. and SAS also report every shareholder.
4. Keep the receipt; banks, notaries and the registries will ask for it.
5. Report changes within 45 or 90 days, and address or marital status changes within 90 days after the calendar year end.

Common traps

The filing clock for a share issue runs from the corporate resolution or act, not from the registry filing.
Changes several tiers up the chain, such as a sale at the foreign holding level, must also be reported.
Paying a dividend to a holder whose owner is not identified exposes the entity to a fine up to the amount paid.
A missing statement suspends the tax compliance certificate (certificado único), which blocks payments from public bodies and many contracts.
Representatives are personally exposed to the fines, not only the entity.

Sources

← Branch of a foreign company in UruguayAnnual corporate compliance in Uruguay: accounts, meetings, AIN filings and ICOSA →