During a capital increase, Qonto must collect certain documents from the natural persons concerned.
These requests do not only target people who participate directly in the operation (investors). They also apply to people who, after the operation, will be considered beneficial owners (BO), even if they did not subscribe themselves.
👉 This verification is part of the obligations to fight against money laundering and terrorist financing (AML-CFT). It allows confirming the identity and situation of any natural person who will hold or control a significant share of the company after the capital increase.
📌 General principles
Depending on the role of natural persons in the operation, different documents may be required. Some general principles apply:
- Valid identity document: required for any natural person whose identity has not yet been verified by Qonto (when opening an account for an existing company or when creating a company), or when the previously submitted document has expired.
- Self declaration form: this document will be made available by Qonto and must be completed and signed by any natural person who becomes a new beneficial owner after the operation.
- Declaration of origin of funds: this document will be made available by Qonto and must be completed and signed by all natural persons who participate in the operation.
- Documentary proof of origin of funds: this document will be requested by Qonto to justify the origin of funds paid in the context of the capital increase. It must be provided for any natural person who will hold at least 25% of the capital after the operation.
ℹ️ Understanding the notion of ultimate beneficial owner (UBO)
A beneficial owner is not solely defined by holding at least 25% of the capital.
A natural person can also be considered a beneficial owner if they:
- hold at least 25% of voting rights, or
- exercise effective control over the company (for example through agreements or a management role).
👉 This is why certain situations in the table below indicate beneficial owners with less than 25% of the capital.
In this case, the required documents are adapted: no documentary proof of origin of funds, which remains reserved for capital holdings ≥25%.
📄 What documents to provide according to the situation of natural persons?
1️⃣ Natural persons who participate directly in the operation
| Beneficial owner status after increase | Capital holding post-operation | Required documents |
|---|---|---|
| Non UBO | <25% |
|
| Becomes UBO | <25% (UBO by voting rights or control) |
|
| Becomes UBO | ≥25% (UBO by capital holding) |
|
| Was and remains UBO | ≥25% (UBO by capital holding) |
|
| Was and remains UBO | <25% (UBO by voting rights or control) |
|
| Was UBO, no longer is | <25% |
|
2️⃣ Natural persons who do not directly subscribe to the operation
In certain cases, people who do not personally invest in the capital increase may still be subject to documentary obligations. This occurs when these people acquire beneficial owner status following modifications induced by the operation.
How does one become a beneficial owner without participating directly?
By dilution effect: A person held 22% of the capital before the operation. The new investors dilute the other partners, but not this person who maintains their participation. They thus move to 26% of the capital and become a beneficial owner.
By indirect participation: A person controls 100% of a company that invests in the capital increase. This investing company acquires 30% of the capital. The natural person thus becomes an indirect beneficial owner of the company.
By modification of agreements: Following new partnership agreements negotiated in the context of the operation, a person acquires effective control rights (nomination rights, veto rights, etc.) without having invested.
📄 Required documents:
If a natural person becomes a new beneficial owner without participating directly in the operation, they must provide:
- Self declaration form (mandatory)
- Valid identity document (only if this person has never been identified by Qonto during previous verifications)
To remember: Only people who become new beneficial owners are concerned. Those who already had this status before the operation and keep it after do not submit any additional documents.
🪪 What identity documents are accepted by Qonto?
As indicated in the previous situations, an identity document may be requested depending on circumstances (identity not yet verified by Qonto or expired document).
When an identity document is required, here is the list of accepted documents:
A valid national identity card
A valid passport
These documents may be issued by any country, except for those listed below for regulatory reasons :
| Continent | Restricted countries |
|---|---|
| Africa | Botswana, Burundi, Congo, Eritrea, Libya, Uganda, Central African Republic, Somalia, Sudan, South Sudan, Chad, Zimbabwe |
| North America | Anguilla, Bahamas, Cuba, Cayman Islands, British Virgin Islands, US Virgin Islands, Nicaragua, Panama, Saint Kitts and Nevis, Trinidad and Tobago |
| South America | Venezuela |
| Asia | Afghanistan, Azerbaijan, Korea, Iran, Iraq, Kyrgyzstan, Macao, Mongolia, Myanmar, Pakistan, Palestine, Philippines, Syria, Yemen |
| Europe | Belarus, Russia |
| Oceania | Nauru, Vanuatu |
⚠️ Important:
- Documents must be valid, readable and complete (not truncated, in color, not blurred).
- Photocopies or partial screen captures are not accepted.
🇺🇸 What additional documents must US Persons provide?
When a person completes the self declaration form and declares being an American national (US Person), additional documents must be provided to comply with FATCA regulatory obligations:
Additional required documents:
- Form W9 (for US Persons) or W-8BEN (for non-US with a tax identification number)
- Proof of tax residence (residence certificate, tax notice, or tax administration certificate)
- Recent proof of address (less than 3 months)
These documents are in addition to other documents already required according to the person's situation (declaration of origin of funds, documentary proof, etc.).
💡 The documents required for legal entity participants are detailed in the following article: What documents are required for legal entity participants.
📩 For any questions, you can contact our team: qonto-ak@qonto.com or consult our FAQ section dedicated to capital increases.