How the regulatory requirements for maintenance of register of members required under section 452 of the Companies Act, 2017 differs from the register of ultimate beneficial owners?

The regulatory requirements for the two different provisions are compared below:

	Circular nos. 16 and 20 of 2018 read with section 453 and 510 of Companies Act, 2017	Circular no. 32 of 2017 read with section 452 of Companies Act, 2017
Applicability	All the companies having natural persons as ultimate beneficial owners (UBO) with not less than 10% ownership/ control rights in that company through legal persons	Every substantial shareholder (having not less than 10% interest), officer of the company or the company itself, having shareholding or other interest in a foreign company or body corporate
Represents	Ultimate Ownership of the company	Investment by substantial shareholders, officers or the company
Information to be maintained by the company	Yes	Yes
Information to be notified to the registrar or Commission	No, unless demanded	Yes
Information is publicly available	No	Yes
Information to be provided to other authorities	Yes, as may be demanded by other authorities from the companies	Yes, by the Commission
Penal provision for non-compliance	Yes	Yes

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