RCBE regime (annex to Law No. 89/2017) · Chapter II · Declaration of the beneficial owner

Article 16 Date of the declaration

Artigo 16.º · Data da declaração

Lei n.º 89/2017 and the annexed Regime Jurídico do RCBE · consolidated text checked 26 October 2026

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The date on which the initial declaration, the annual confirmation declaration or the declaration of changes is made shall be deemed to be the date of its electronic submission.

Considera-se como data da realização da declaração inicial, da declaração de confirmação anual ou da declaração de alterações a data da respetiva submissão por via eletrónica.

What we checked in this article

The rule that the date of electronic submission is deemed the date of the initial, annual confirmation and change declarations is retained.

Need to file or update the RCBE declaration? Article 16 is where it starts.

We file initial RCBE declarations, updates and annual confirmations for Portuguese companies with foreign owners, and map the ownership chain so the beneficial owner is identified correctly. Fixed fee, done in English.

Unofficial English translation prepared by BCA Portugal for reference. Only the Portuguese text published in the Diário da República has legal force. Editorial notes are ours and are not part of the statute.

Applying the law

The RCBE declaration, filed correctly the first time

A missing or wrong declaration blocks dividend payments, public contracts and bank onboarding. Send us the ownership chart; we identify the beneficial owners, file the declaration and keep it current.

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