Lesson 2 — Configuring the regime: threshold, basis, durations
Article 5(1) defines a real beneficiary as the natural person who owns or ultimately controls the legal person through direct or indirect ownership of 25 per cent or more. Read that phrase slowly, because the whole configuration turns on it. Source: Cabinet Resolution 109/2023, Art. 5(1).
The threshold is inclusive. Someone holding exactly 25% is a real beneficiary. Not "borderline", not "arguably" — the text says "25 per cent or more", and 25% is 25 per cent or more. Odoone seeds the Beneficial ownership threshold at 25% under Settings › Odoone › UBO Register and applies the comparison inclusively. The field is configurable because a future Cabinet resolution can move the number; it is not there so that you can tune it to a level you find comfortable.
The deadline basis is an honest assumption, and you should know that. The Resolution says "days" without stating whether they are calendar days or business days. The module treats them as calendar days by assumption, not as verified law, and exposes that choice as a setting so a later ruling can change it without a code change. If your advisor reads it differently for your case, change the setting — do not work around it in your head.
Each statutory duration has its own field, because the durations genuinely differ. There are eleven-plus of them; these seven are the ones you will meet:
| Duration | What it covers | Where it comes from |
|---|---|---|
| 60 days | Creating the initial register, from the Resolution's implementation or from the entity's establishment | Arts. 8(1) and 11(1) |
| 15 days | Notifying a change to the register, from the day you become aware of it | CR 109/2023 |
| 15 days | A nominee board member disclosing that status, from acquiring it | CR 109/2023 |
| 30 days | The transitional duty for a nominee board member already holding that status at publication | CR 109/2023 |
| 14 days | Supplying additional data the Registrar asks for — note it is 14, not 15 | CR 109/2023 |
| 30 days | Handing the registers to a liquidator | CR 109/2023 |
| 5 years | The liquidator's retention of those records | CR 109/2023 |
Worked example. Al Mirfa Contracting LLC was established on 3 March 2026. On calendar days, the 60-day clock in Articles 8(1) and 11(1) expires on 2 May 2026. In July the company learns of an ownership change on 14 July 2026, so the 15-day notification runs to 29 July 2026. In October the Registrar asks for additional data on 5 October 2026: that one is 14 days, not 15, so the date is 19 October 2026. Three obligations, three different arithmetic rules, one register.
Finally, enable UBO Register Reminders under Settings › Technical › Scheduled Actions. It ships switched off, on purpose, so that installing a module never starts sending mail on your behalf.
The failure mode. "We configured everything and no reminder ever arrived." The scheduled action is still off. It is the one post-install step that is easy to skip, because nothing on the register screen tells you it is missing.