Beneficial Ownership Registers in the EU: What Changes for Companies

Gregory Lutsenko

21.07.2025 | 6 min read

Updated: 22.10.2026

There is no single EU register of beneficial owners and no EU-wide platform for filing declarations. Each Member State keeps its own central register, and a company files its data in the country where it was created. The national registers are connected through BORIS, a search service that does not accept filings. For corporate ownership transparency and AML compliance for businesses, this means one thing: the disclosure of beneficiaries in Europe is a national procedure under common EU rules.

COREDO has supported companies with AML compliance in the EU since 2016. This article sets out the rules in force in October 2026 and the changes due by 10 July 2027.

Is There a Single EU Register of Beneficial Owners?

No. EU anti-money laundering law requires every Member State to hold beneficial ownership information in a central register. Member States had to set up these registers for companies by 10 January 2020. The Commission had to ensure their interconnection by 10 March 2021. The connection runs through the European Central Platform created by Directive (EU) 2017/1132 on company law. The system, BORIS (Beneficial Ownership Registers Interconnection System), is decentralised: it links the national registers with the European e-Justice Portal and works as a central search service.

Which Companies Must Disclose Beneficiaries in the EU

Corporate and other legal entities incorporated in a Member State must obtain and hold adequate, accurate and current information on their ultimate beneficial owners. A beneficial owner is the natural person who ultimately owns or controls the entity. An ownership interest of more than 25 % is an indication of ownership, and a Member State may set a lower percentage. Control through other means counts as well. Companies listed on a regulated market with adequate disclosure rules fall outside this definition. If no such person can be identified, the senior managing officials are treated as the beneficial owners.

The solution developed by COREDO for clients with multi-level holding structures allows for the correct reflection of the ownership chain and avoids declaration errors.

Beneficial Ownership Registers in the EU: What Companies File

Each register is national, so the form and the filing deadline depend on the country. EU law sets the common frame: the information in the register must be adequate, accurate and current. Banks and other obliged entities report any discrepancy between the register and their own information.

What Information and Documents Need to Be Submitted to the Register

From 10 July 2027 the EU regulation on anti-money laundering lists the information on a beneficial owner in detail:

• all names and surnames, place and full date of birth, residential address, country of residence and nationality;
• the number of an identity document, such as a passport, and a personal identification number where one exists;
• the nature and extent of the beneficial interest, through ownership or control, and the date from which it is held;
• where the structure contains more than one entity, a description of the structure with their names and the shares held.

Deadlines for Beneficial Ownership Filings

Until 10 July 2027 the deadline is national: in the Czech Republic, for example, the registering entity files without undue delay after the relevant fact arises. From 10 July 2027 the regulation sets one rule for the whole EU. A legal entity reports its beneficial owners without undue delay after its creation, and any change within 28 calendar days at the latest. At least once a year, it also checks that its information is up to date.

BORIS: How National Registers Are Connected

BORIS connects the national registers and the European e-Justice Portal through the European Central Platform. Each Member State decides what it shows through BORIS under its own access rules.

How a Group Files in Several Countries

• find the country where each entity was created: its register is the place of filing;
• check that country's form, deadline and supporting documents;
• keep one ownership chart for the whole group and use it for every filing;
• after each change, update the information in every register concerned.

Integration of AML Systems with EU Registers and Best Practices

Banks and other obliged entities use the registers in customer due diligence. They may not rely on the register alone and apply a risk-based approach. Best practices include:

• comparing register extracts with the company's own records and the bank's KYC file;
• regular audits of the corporate structure.

Responsibility and Risks: Fines for Non-Disclosure of Beneficiaries

EU law requires effective, proportionate and dissuasive measures or sanctions for breaches. The type and amount of sanctions are set by national law. The Czech law on the register of beneficial owners (zákon č. 37/2021 Sb.) shows what this means in practice:

What Happens for Concealing Beneficiary Information in Europe

Under the 2024 directive, which Member States transpose by 10 July 2027, registers get stronger powers. They verify the information and can carry out checks, including on-site inspections. Where the information is wrong, the register can withhold or suspend the certificate of proof of registration and impose pecuniary sanctions. Registers also check whether an entity or its beneficial owners are subject to targeted financial sanctions and mark such cases in the register. The solution developed by COREDO for clients with an international structure includes regular audits of corporate structure and automated data checks to minimize such risks.

Typical Errors in Declaring Beneficial Owners

COREDO’s experience shows that the most common errors in declaring beneficial owners are related to:

• incorrect identification of the ultimate beneficiary;
• untimely data updates with structural changes;
• inconsistency of data with internal KYC procedures and bank requirements.

Compliance procedures for international companies should include regular data checks and staff training on new EU standards.

Who Can See Beneficial Ownership Data After the CJEU Ruling

The fifth AML directive required Member States to open the beneficial ownership data of companies to any member of the general public. On 22 November 2022 the Court of Justice of the EU (Grand Chamber) declared this rule invalid in Joined Cases C-37/20 and C-601/20. The Court held that general public access is a serious interference with the rights to respect for private life and to the protection of personal data. In 2024 the EU replaced the rule. The information is now accessible in all cases to competent authorities and financial intelligence units, and to obliged entities for customer due diligence. Any person or organisation with a legitimate interest also has access. Member States had to transpose this change by 10 July 2025.

Who Has a Legitimate Interest

The 2024 directive names the main groups that are deemed to have a legitimate interest:

• journalists and other media whose work is connected with preventing or combating money laundering;
• civil society organisations, including non-governmental organisations and academia, with the same connection;
• persons likely to enter into a transaction with the entity who wish to rule out its link to money laundering.

These persons see the name, month and year of birth, country of residence and nationality of the beneficial owner, and the nature and extent of the interest held. Member States had to transpose these access rules by 10 July 2026. From 10 November 2026 a register must answer an access request within 12 working days.

What Changes From 10 July 2027

The 2024 AML package consists of Regulation (EU) 2024/1624 and Directive (EU) 2024/1640. The regulation applies directly in all Member States from 10 July 2027, and the directive must be transposed by the same date. From that day, Directive (EU) 2015/849 is repealed. The threshold becomes 25 % or more of the shares, voting rights or other ownership interest, counted on every level of the chain. For categories of entities with higher risk, the Commission may later set a lower threshold, as a rule no higher than 15 %.

Protection of Beneficiaries’ Personal Data and GDPR

The 2022 ruling rests on the rights to private life and data protection: access to the register must be proportionate. Registers keep records of who accessed the information on the basis of a legitimate interest, and a beneficial owner can request them under the GDPR right of access. In exceptional cases national law exempts the information from access. Examples are a disproportionate risk of fraud, kidnapping, blackmail or violence for the owner, or an owner who is a minor. Such exemptions are decided case by case.

How to Ensure Data Protection for Beneficiaries in New Conditions

To ensure the protection of beneficiaries' personal data, COREDO recommends:

• using automated verification systems with data encryption;
• restricting access to owners' documents within the company to authorized individuals only;
• regularly performing compliance audits to GDPR and FATF standards.

Restrictions and Exceptions: When a Company May Not Disclose Beneficiaries

The exceptions are narrow. Under the current definition, companies listed on a regulated market with adequate disclosure rules are outside it. From 10 July 2027 the exception becomes narrower. It will cover listed companies only where control is exercised exclusively by natural persons with voting rights and no other entity is part of the ownership or control structure. An exemption from access is different: the company still files, and only access to the information is restricted.

Practical Steps for Companies: How to Prepare for New EU Requirements

Implementing new procedures requires a systematic approach and a revision of internal regulations. COREDO's experience shows that successful adaptation is only possible with close interaction among legal, compliance, and IT departments.

Action Algorithm for Businesses to Implement New Procedures

1. List every entity of the group and the country where it was created.
2. Identify the beneficial owners of each entity: 25 % or more under the 2027 rules, and any control through other means.
3. Compare each national register entry with the ownership chart and the bank's KYC file.
4. Set an internal rule to report every change within 28 calendar days.
5. Check the beneficial ownership information at least once a year.

Automation Tools and Best Practices for Compliance with New Requirements

The most effective tools for complying with new EU requirements are:

• one ownership chart of the group, kept current by a designated employee;
• electronic document management and electronic signature systems;
• services for automatic data verification and monitoring of structural changes.

Key Conclusions and Recommendations for Entrepreneurs and Leaders

There is no single EU register: companies file with national registers, and BORIS connects them. Since the 2022 ruling, EU law no longer requires public access: beyond authorities and obliged entities, it guarantees access to persons with a legitimate interest. From 10 July 2027 the AML package sets common rules on beneficial owners, deadlines and the powers of registers. Companies that keep their information accurate and current receive:

• access to financial services and investments;
• reduced corporate risks and reputational losses;
• increased transparency for investors and partners.