When you join Coverflex, we’ll ask you to submit some documents so our payment services partner, Pecunpay, can check your business, as part of anti-money-laundering regulations. These documents are mandatory to finish your onboarding process.
If they’re not sent within 15 days your account will be blocked, meaning you won’t be able to add funds to your employees’ accounts. In this article we explain what’s necessary so you can submit the right documents.
Please know that we only accept documents in PDF, JPG and PNG formats, and we don’t accept files larger than 25MB.
Summary:
- KYB Form
- Deed of Incorporation
- RCBE
- Managers' ID documents
- Special cases
KYB Form
About a week after the beginning of your Coverflex subscription, we will send you a form with the details of your company on it. You should check that this is completed correctly, especially the details of the shareholders, and have it signed by the director/manager named on the form.
If we are not able to identify your company’s shareholders, we may ask you to complete the form with these details. You should fill in the grid with the name, tax ID number, country of residence and percentage share of each shareholder so that the percentages add up to 100%.
We accept handwritten signatures and also digital ones done with all major digital signature providers. The Autenticação service, provided by the Portuguese government, is simple to use and free of charge.
Note that all three pages of the form should be returned in one PDF document. Pecunpay will not accept the submission of the signature page alone, although it is not necessary to initial every page.
Deed of Incorporation
We need a valid deed of incorporation for your business. The expiry date of the certificate is shown at the end. The certificate must be valid on the day of its submission to Pecunpay, which means that if it is no longer valid when we receive the signed form back from you, you will need to submit a renewed certificate. We can accept PDF deeds or deed codes, and we accept deeds in Portuguese and English.
If your deed of incorporation has expired, you can easily renew it online.
Your deed should be:
- In PDF format or in the form of the corresponding code
- In English or Portuguese
- Within the validity date shown
RCBE
The Registo Central do Beneficiário Efetivo is a document which shows all of the beneficial owners of your company. We need the full version, which means that if the document shows that it has five pages, you will need to submit all five. In this case, we cannot accept the code.
You can submit either a PDF of what's shown when you submit the declaration or the e-mail which is received afterwards. If you are considering submitting the e-mail, know that .msg files and .eml files are not accepted by the system. You can easily convert these files to PDF documents by choosing "Print" in the menu of your browser or e-mail programme, and then “Save as PDF”.
The information on the RCBE must match the information on the Deed of Incorporation. This means that if your deed shows that your company has three managers, but the RCBE shows two, the out of date document will need to be updated so that they match.
If you do not have an RCBE, or the details on your RCBE are out of date, you can easily submit a new declaration online.
Your RCBE should be:
- In PDF Format (NOT the code)
- Complete, with all its pages
- Up to date, so it matches the information on the deed
ID Documents of the managers
We require copies of the valid ID document for every manager or director of the company. The names of the managers/directors of your company are listed on the Deed of Incorporation. Documents submitted must be in colour, and must be valid. Documents are not valid beyond the expiry date shown on them. All of the information on the documents must be easily read, and there should be no blur or reflections on the copies. Truncated or obscured documents will not be accepted.
We accept copies of passports, copies of plastic citizen cards from any EU country (front and back), and digital citizen cards issued by the Portuguese government in PDF format.
Note that even if your company only requires one signature to make company decisions, all of the company managers will still have to submit their documentation in line with the regulations.
Documents may be marked as “copy” or have lines drawn on for security reasons, if preferred, but such marks must not obscure the details on the document.
Your Manager ID documents should be:
- In colour
- Clear, without blur or reflections
- Within the validity period
Special Cases
Associations
Associations do not have Deeds of Incorporation. In this case, you should submit the Constitution, the Statutes, and the Minutes of the most recent meeting which shows the names of the people in the governing bodies of the association. All other documents (RCBE, manager ID documents and the KYC form) should be submitted as usual.
Sole Traders
Sole traders do not have Deeds of Incorporation or RCBEs. In this case, the declaration of activity issued by the Portuguese tax authorities should be submitted. It should have the words “declaração de início de atividade” on it. No other document from the tax authorities is acceptable, nor are screenshots from the tax portal. Some declarations must be accompanied by a letter from the authorities which is sent to your home. These are clearly identified in the top right corner of the document. If this is your case, you must also upload a copy of the letter.
You must submit a copy of your ID document as normal.
You may also be required to submit an invoice you have issued recently to demonstrate that you are still actively carrying out business.
Foreign Companies
Foreign companies have tax numbers starting with 9 and may be known as a branch or a sucursal. These companies may have Deeds of Incorporation showing their legal representative in Portugal. If this is the case, this document must be uploaded along with the legal representative’s ID document. You must also submit the RCBE.
Other foreign companies may not have the deed of incorporation. If this is the case, we ask that the deed of incorporation from the company’s home country is uploaded along with proof that the company has obtained its Portuguese NIF from the authorities. This document, issued by the National Register of Companies, shows this logo:
Foreign deeds of incorporation must be in English, Spanish or Portuguese, otherwise they should be accompanied by a translation into one of these languages.
Related articles: Setting up your Coverflex account