Beneficial owner declaration — decree 26-163 (CNRC)

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decree 26-163 beneficial owner chain of control CNRC register 20 % threshold annual confirmation internal register decree 23-429 repealed

What this is. An engagement that produces three things, in this order: an established chain of control — who ultimately owns or decides; a file that proves it — articles of association, foreign registers, share transfers, identity documents; and a filed declaration on the model annexed to decree 26-163, followed by the internal register and the annual confirmation. We issue nothing: the register belongs to the CNRC. What we ensure is that what is entered there matches the reality of your capital — and holds up against a request for rectification.

What decree 26-163 changed

Executive decree no. 26-163 of 20 April 2026, published in Official Journal no. 32 of 4 May 2026, repeals decree 23-429 (article 29) and rebuilds the scheme. Three out of four companies that call us about this are still working from the old form — the one that opened with the question “is the beneficial owner among the persons named in the registration application?”. That question no longer exists.

Point	Decree 23-429 (repealed)	Decree 26-163 (in force)
Scope	Legal persons governed by Algerian law	Legal persons and legal arrangements — trusts and equivalent entities
Form models	One single model	Five models: commercial companies, civil companies, associations and non-profits, wakfs, legal arrangements
Form structure	Yes/no question, then two separate paths	Direct / indirect boxes, then the three control tests
Declarant details	Summary identity	National ID number, identity card or passport with places and dates of issue and expiry, phone, email, capacity
Deadline	During the following month	Thirty days from incorporation, registration or amendment
Recurring obligation	None	Annual confirmation before 31 December
Internal register	Ad hoc register mentioned	Detailed ad hoc register (art. 17), accurate and updated, kept for five years
Filing channel	Electronic possible	Declaration submitted electronically on the annexed models (art. 10)

Two additions weigh more than the form itself. First the annual confirmation: a company perfectly compliant in March is in default on 1 January if no one confirmed before 31 December. Second the internal register of article 17, which the administration can rely on independently of the declaration filed — the two must say the same thing.

Who files, and on which model

The test is not the nationality of the shareholders but the law governing the legal person: an Algerian limited liability company wholly held from abroad is fully covered — indeed it is the textbook case the scheme targets, since it forces you to look through interposed legal persons down to the natural person. Outside the scope: legal persons whose share capital is wholly or majority State-held, and legal persons governed by public law (article 4).

You are	Applicable model	Authority receiving the basic information
SARL, EURL, SPA, SNC, SCS…	Commercial companies	National trade register centre
Civil company (property, professional…)	Civil companies	Directorate general of taxes
Association, foundation, NGO operating in Algeria	Associations and non-profit organisations	Ministry of the interior
Wakf	Wakfs	Ministry in charge of wakfs
Trust or equivalent foreign entity operating in Algeria	Legal arrangements	Directorate general of taxes

The declaration itself is filed with the CNRC services in whose jurisdiction the registered office sits (article 8), and a separate form is required for each beneficial owner where there is more than one (article 10).

A free tool for the form. If your situation is simple and you only need the document, our beneficial owner form generator reproduces the five 2026 models, fills in inside your browser and prints — no data is transmitted. The engagement below starts where the tool stops: when you have to establish who the beneficial owner is, and prove it.

Identifying the beneficial owner: three tests, in order

Article 15 sets a cascade to be applied in order, with no step skipped:

Ownership. Any natural person holding, directly or indirectly, a share equal to or above 20 % of the capital or of the voting rights. Indirect counts exactly as direct: 1 % in own name plus 99 % through a foreign company makes 100 %.
Effective control. If the first test identifies no one with certainty, the person who exercises, in fact or in law, control over the management, administration or the general meeting — by determining the content of decisions, or by holding the power to appoint and remove the majority of directors.
The legal representative. A backstop: if neither (1) nor (2) produces an answer, the beneficial owner is the natural person holding the capacity of legal representative.

Two rules complete the cascade, and in practice they are the ones that get forgotten. Article 16: where the holder is a legal person, it is its beneficial owner that must be identified and retained. And the closing rule of article 15: natural persons exercising ultimate control must be identified whether or not they hold a stake above the threshold. The 20 % threshold opens the search; it does not close it.

What the engagement covers

Scoping. Whether the entity is covered or out of scope, which of the five models applies, the authority receiving the basic information, and the exact starting point of the thirty-day period — incorporation, registration, approval or start of activity as the case may be.

Reconstructing the ownership and control chain. Reading the articles, the shareholder register, transfer deeds and shareholders' agreements; looking through interposed legal persons, foreign ones included, down to the natural person; and a reasoned application of the test retained — ownership, effective control or legal representation.

Building the evidence file. The decree requires the additional documents needed to establish the chain, particularly where the structure is complex or involves several countries: foreign beneficial ownership registers, trade register extracts from the country of origin, apostille or legalisation, sworn translations.

Drafting and filing. The official 2026 form completed field by field — one copy per beneficial owner —, with a scoping note explaining the test applied, filing with the CNRC of the registered office, and follow-up on the register officer's observations, who may require rectification within a maximum of fifteen days.

Internal ad hoc register. Setting up the register required by article 17 — basic information and beneficial owner information, accurate, sufficient and up to date —, aligned word for word with what was declared, together with the five-year retention rule.

Keeping it alive. A calendar for the two recurring deadlines: updating within thirty days of any change — share transfer, change of manager, movement in the ownership structure abroad — and the annual confirmation before 31 December.

What the engagement is not. We enter nothing on the register. Keeping it is the CNRC's function, and the register officer retains the power to verify and require rectification. Nor do we certify foreign documents. We identify which must be apostilled or legalised, and by whom. No obligation of result is undertaken on any administrative decision.

Deadlines and calendar

Event	Deadline	Basis
Incorporation, registration, recording or approval	30 days	Art. 12 a)
Start of a legal arrangement's activity in Algeria	30 days	Art. 12 a)
Change to entity or beneficial owner information	30 days	Art. 12 b)
Annual confirmation that the information is accurate	Before 31 December, every year	Art. 12
Rectification required by the register officer	15 days maximum	Art. 13
Notification to the CNRC by a reporting entity	15 days	Art. 9
Reporting a breach or an incomplete declaration	72 hours	Art. 24
Retention of the internal register and supporting documents	5 years	Art. 17 and 19

The period runs from the event, not from the day you become aware of it. For a registration, the practical starting point is the date of entry in the trade register. Filing the declaration on the day you collect the extract saves a second trip, and puts the deadline on your side.

An ownership chain that crosses a border?

Beneficial owner analysis and the list of documents to gather. First consultation free, reply within 24 hours.

Scope my declaration +213 550 02 02 87

Frequently asked questions

Our Algerian company is held by a foreign company: who is declared?

We already filed under decree 23-429: do we start again?

No shareholder reaches 20 %: so there is no one to declare?

Are associations and wakfs really covered?

What is the exposure for not filing?

Sources and references

Executive decree no. 26-163 of 20 April 2026 on the public register of beneficial owners of legal persons and legal arrangements — Official Journal no. 32 of 04/05/2026, pages 4 to 20 including annexes (full text read) — Official Journal of the Algerian Republic (JORADP) · Verified on 30/08/2026
Executive decree no. 23-429 of 29 November 2023 on the public register of beneficial owners of legal persons governed by Algerian law — Official Journal no. 76 of 30/11/2023, repealed by article 29 of decree 26-163 — Official Journal of the Algerian Republic (JORADP) · Verified on 30/08/2026
Communiqué on the beneficial owner declaration: scope, filing at the CNRC's 65 local offices or through the electronic platform, special register and five-year retention, reference to article 32 bis 1 of law 05-01 as amended by law 25-10 — Ministry of internal trade and national market regulation · Verified on 30/08/2026
Law no. 05-01 of 6 February 2005 on the prevention of and fight against money laundering and terrorist financing, as amended — the statutory basis of the scheme (articles 8, 8 bis and 27 bis) — Financial Intelligence Processing Unit (CTRF) · Verified on 30/08/2026

Beneficial owner declaration with the CNRC