Danish Lawyers Required to Disclose Client Identity Information on Collective Client Bank Accounts

Strategic Insights -

As of January 1, 2026, lawyers in Denmark will be required to make identification information available to their banks on clients who have funds in collective client bank accounts. This new provision is part of an amendment to the Money Laundering Act, which was adopted by the Danish Parliament in June 2025. The amendment introduces a new section, 38 b, which obliges lawyers to obtain and disclose identity information on the beneficial owner of the funds in a collective client bank account. However, there will be an adjustment to the requirements for obtaining identity information on legal persons, exempting the need to identify and verify the beneficial owners of legal persons.

Key Takeaways:

  • As of January 1, 2026, lawyers in Denmark will be required to disclose identification information on clients who have funds in collective client bank accounts.
  • The new provision, section 38 b of the Money Laundering Act, obliges lawyers to obtain and disclose identity information on the beneficial owner of the funds.
  • An amendment to the preparatory work for section 38 b will exempt the need to identify and verify the beneficial owners (natural persons) of legal persons.
  • The legislative preparations for section 38 b will be amended to remove the requirement for identity information on the beneficial owner(s) of legal persons.
  • The Danish Bar Association will publish guidance on the new provision in October 2025 and will hold information meetings on November 18, 2025, in Kolding and Aarhus, and on November 21, 2025, in Copenhagen.

Statistics:

  • January 1, 2026: Date when the new provision will come into effect.
  • June 2025: Month when the Danish Parliament adopted the amendment to the Money Laundering Act.
  • October 2025: Month when the Danish Bar Association will publish guidance on the new provision.
  • November 2025: Month when the Danish Bar Association will hold information meetings on the new rules.
  • October 29, 2025: Date of the first information meeting in Aalborg.
  • November 18, 2025: Date of the information meetings in Kolding (morning) and Aarhus (afternoon).
  • November 21, 2025: Date of the information meeting in Copenhagen.

Sources:

  • "Danish Bar and Law Society's News Release" (translated version available from the Danish Bar Association's website: [https://www.advokatsamfundet.dk/](https://www.advokatsamfundet.dk/)).