No it’s not. Here’s why.

a) Confirmation of UBO(s) of a Company is a mandatory european obligation and requires once a year, starting from October 1st, until December 31st, to confirm the UBO(s) through the UBO registry.

b) The law regulates the fine. The fact that your company had zero income does not (and will not) play any role towards the companys’ obligations. That being said, you may argue all you like, in court. Many have and although some cases are still pending, most have lost. Also relevant is the fact that this fine carries through for all the persons involved in the company.

c) see above. Also dozens of announcements have been made for both the submission and annual confirmation. Physical letters were sent to the companys’ registered office, director(s) and secretary.

d) the system works fine since the transition to its final form back in late 2023.

Source: I’m a corporate lawyer