I. DEADLINE FOR SUBMISSION THE STATEMENT CONCERNING THE REAL BENEFICIARY BEFORE THE EMERGENCY STATE ESTABLISHMENT
The moment of filing the statement regarding the real beneficiary differs depending on companies already established or companies that are set up after the entry into force of the law no. 129/2019.
Thus, for companies already established at the date of entry into force of the law, the preparation and submission of the statement regarding the real beneficiary must be made:
- within an imperative term of 12 months established by the same law, with a starting date from its entry into force (the deadline to be fulfilled on July 21, 2020);
- annually, within 15 days from the approval of the annual financial statements;
- at any change of the company charter, within 15 days from the date on which it intervened.
For companies that are established after the law comes into force, the statement regarding the real beneficiary must be submitted to the trade register:
- at the time of registration in the trade register, along with the submission of the necessary documentation in order to achieve this purpose;
- annually, within 15 days from the approval of the annual financial statements;
- at any change of the company charter, within 15 days from the date on which it intervened.
II. DEADLINE FOR SUBMISSION THE STATEMENT CONCERNING THE REAL BENEFICIARY AFTER THE EMERGENCY STATE ESTABLISHMENT
In the current context of the state of emergency in Romania, decreed as a result of the infection with COVID-19 virus, the Government adopted the Emergency Ordinance no. 29/2020 regarding some economic and fiscal budgetary measures, through which it also brought some amendments to Law no. 129/2019.
The changes made by this ordinance are reflected on the deadlines for submitting the statement regarding the real beneficiary, which is suspended during the entire period of emergency, in other words until 14.04.2020 or until another date assuming that the state of emergency would be extended.
The other change regarding this matter refers to the fact that the deadline for submission of the statement regarding the real beneficiary of the company, regardless of the reason on which it is based, is extended by 3 months from the date of cessation of the state of emergency established by the Presidential Decree no. 195/2020.