COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.
Alena Mach
18.08.2025 | 6 min read
Updated: 24.10.2026
Concealed beneficial owners and opaque ownership structures have featured in many major money-laundering cases in Europe in recent years. That is why beneficial ownership transparency has become a core part of the EU's 2024 anti-money laundering package, whose main rules will apply from 10 July 2027. Today, transparency of business owners and strict AML compliance for companies are becoming not just regulatory requirements, but a strategic imperative for any international business planning to register legal entities in Europe, Asia, or the CIS.
In recent months, the COREDO team has observed how the tightening of rules on beneficial ownership disclosure is changing not only the legal landscape but also approaches to risk management, investment attractiveness, and corporate strategy. The new requirements for beneficial owners in Europe, the interconnection of national UBO registers across the EU, and the digitalization of compliance are challenges that require not only a deep understanding but also practical solutions.
Are you prepared for the fact that control over the company and beneficial ownership is under constant digital monitoring, and liability for concealing information about the ultimate beneficial owner will become one of the key business risks? If your answer is not definitive, I recommend reading this analytical guide to the end: here you will find not only strategic ideas but also practical recommendations tested by COREDO's experience in the EU, Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore, and Dubai.
Requirements for Beneficiaries in Europe
Requirements for beneficiaries in Europe are tightening: companies are required to ensure ownership transparency, adhere to new AML standards, and regularly update information on ultimate owners. To comply with these rules, it is important to clearly understand who is recognized as the ultimate beneficiary and how to correctly identify them within European legislation.
How to Identify the Ultimate Beneficiary
Under the rules in force today, an ultimate beneficial owner (UBO) is a person who owns more than 25% of the company. It is also anyone who controls the company by other means, even without formal ownership. From 10 July 2027, the EU Anti-Money Laundering Regulation (AMLR) sets the ownership threshold at "25% or more". It also allows the European Commission to set a lower threshold, of no more than 15%, for higher-risk categories of companies. At COREDO, we have encountered cases where, for example, veto rights on the board or the ability to appoint key managers were recognized by regulators as signs of control requiring disclosure in the beneficial ownership register.
Special attention is paid to cross-border ownership structures and nominee services. If the ownership chain includes a foreign company or a nominee holder, disclosure of information about the beneficiary becomes mandatory, and the distinction between the beneficiary and the controlled foreign company becomes crucial for Due Diligence and KYC procedures. COREDO's practice confirms: ignoring these nuances leads to account blocks and license denials, especially in financial services, crypto, and forex sectors.
UBO Registers in the EU: Disclosure
We are entering the era of automated platforms for submitting data on beneficiaries. There is no single EU register: each Member State keeps its own central register of beneficial owners, and EU law requires these registers to be interconnected. Under the AMLR, from 10 July 2027 a company must report any change in its beneficial owners to the register within 28 calendar days and verify its beneficial ownership information at least once a year.
At COREDO, we have developed solutions that allow integrating clients' corporate systems with data submission platforms, significantly reducing processing times and minimizing the risk of errors. Nevertheless, the expansion of access to the UBO register (including for banks, auditors, and regulators) requires special attention to the storage and protection of beneficiary data: violations in this area can lead to corporate sanctions and legal prohibitions.
AML Compliance: New Requirements
The requirements for AML compliance are becoming stricter: companies must not only strengthen internal procedures but also be prepared for constant checks and the collection of additional data about clients and their transactions. In this context, updated AML directives and KYC procedures acquire special significance, where key changes appear that need to be known today.
AML Directives and KYC Procedures: What's New
The EU's 2024 anti-money laundering package, the AMLR (Regulation (EU) 2024/1624) and the Sixth AML Directive (Directive (EU) 2024/1640), tightens AML compliance requirements for companies. Most of its rules will apply from 10 July 2027. Now, every stage of legal entity registration in Europe is accompanied by mandatory due diligence and KYC procedures, and the role of the compliance officer becomes key for corporate reporting.
A real case from COREDO's practice: when obtaining a payment services license in Estonia, the client had not only to disclose the entire ownership chain but also confirm the absence of anonymous beneficiaries, provide documents confirming the source of funds, and implement automated transaction monitoring systems. This approach is becoming standard for all companies operating in the financial sector of the EU, UK, and Singapore.
Liability for Violation of UBO Register Requirements
Penalties for breaching beneficial ownership disclosure rules are set by national law. In the Czech Republic, for example, the fine is up to CZK 500,000. A company also may not pay out profits to an unregistered beneficial owner, who may not vote at its general meeting. Liability for concealing a beneficiary now extends not only to directors but also to compliance officers, and court prohibitions for violating beneficiary disclosure can block account operations and asset transactions.
The solution implemented by COREDO for a client in Czechia minimized the risk of sanctions for non-compliance with AML directives: a comprehensive check of the ownership structure was conducted, an automatic notification system for data updates was implemented, and employee training on new corporate compliance standards was organized.
Implementation of New Requirements for Business
The implementation of new requirements for business entails significant changes in legislation and operational regulations. To minimize risks and comply with established norms, companies need to timely familiarize themselves with new obligations and correctly implement all necessary procedures.
Detailed information on how to update beneficiary details is provided in the next section.
How to Update Beneficiary Data
The transition to automated platforms demands a clear procedure for working with the UBO register. In practice, COREDO recommends the following algorithm:
- Conduct an audit of the company's ownership structure, identifying all individuals with substantial control and ownership share.
- Prepare a package of documents for identifying the ultimate beneficiary: passport, proof of address, ownership documents, corporate resolutions.
- Enter or update data in the automated beneficiary register via the national platform or integrated corporate system.
- Annually confirm the accuracy of the information, track changes, and promptly respond to regulatory requirements.
Best practices in managing ownership structures show: integrating automated reminders and regularly auditing beneficiary data help avoid fines for untimely updates and automatic removal from the company register.
Thus, the transition to automated platforms for preparing and maintaining the UBO register creates a base for effective compliance process automation.
Automation of Compliance Processes
Digitalization of compliance is a key trend. COREDO's team is implementing modern solutions for automating the submission and monitoring of beneficiary data: from integration with government platforms to using cloud services for information storage and protection. Special attention is paid to the security and confidentiality of beneficiary data, with encryption, multi-level authentication, and regular IT system audits becoming mandatory elements of corporate compliance.
In a case for a COREDO client in the UK, implementing a digital platform reduced compliance costs by 30% and accelerated the process of updating beneficiary data from 10 days to 48 hours, significantly improving the company's corporate transparency rating.
New Requirements and the Investment Climate
In the context of emerging new requirements and a changing investment climate, companies have to consider increasingly complex regulation and business environment parameters. These changes affect not only business strategy but also directly impact corporate risks and tax consequences for investors and entrepreneurs.
As a result, a new set of challenges is emerging that requires increased attention to corporate risk management and tax planning.
Corporate Risks and Tax Consequences
Disclosure of beneficiary information directly impacts the investment climate. International banks and partners are increasingly requesting confirmation of business owner transparency when opening accounts and closing deals. COREDO observes that companies promptly implementing new corporate governance standards and ownership chain disclosure gain access to more favorable banking financing conditions and international investments.
On the other hand, the new requirements also present tax risks for beneficiaries, especially in cross-border structures. Special attention is paid to double taxation avoidance agreements and their impact on the beneficiary's status. COREDO's practice shows: timely auditing of the ownership structure and correct information disclosure minimize the risks of tax assessments and sanctions by regulators.
Benefits and Exemptions for Different Companies
There are categories of companies with special disclosure conditions, such as funds, trusts, and certain types of holding structures. Low-risk entities and specific sectors (e.g., innovative startups) are provided exemptions on the amount of disclosed information. However, the final decision always remains with the EU regulatory bodies and national regulators.
COREDO's team recommends closely monitoring updates in corporate transparency ratings and consulting with specialized lawyers when choosing an ownership structure to not miss available benefits and avoid unnecessary risks.
Practical Recommendations for Business
| Change/Requirement | What Should Businesses Do? | Timelines/Frequency | Responsibility/Sanctions |
|---|---|---|---|
| Annual Confirmation of UBO Data | Prepare documents, update data in the register | Changes within 28 days; verification at least once a year (AMLR, from 10 July 2027) | Fines and other sanctions under national law |
| Implementation of Digital Submission Platforms | Integrate corporate systems | During implementation | Corporate sanctions |
| Expansion of Substantial Control Criteria | Conduct an audit of the ownership structure | From 10 July 2027 (AMLR) | Directors' responsibility |
How to Minimize Compliance Risks?
- Conduct an audit of the ownership structure with the involvement of external experts.
- Implement automated platforms for beneficiary data submission and monitoring.
- Regularly train employees on new AML and EU corporate law requirements.
- Use digital solutions for storing and protecting data, complying with international standards.
- Maintain constant monitoring of changes in legislation and corporate sanctions lists.
Metrics for UBO and AML Procedure Effectiveness
- Time to update beneficiary data (target: <48 hours).
- Number of identified errors in the ownership structure (target: 0).
- Percentage of successfully confirmed data in the automated register (target: 100%).
- Number of sanction or fine cases (target: 0).
Compliance Officer's Checklist
- [ ] Conducted audit of the ownership structure, identifying all UBOs.
- [ ] Updated data in the automated beneficiary register.
- [ ] Implemented a digital compliance platform.
- [ ] Employees trained on AML and UBO reporting.
- [ ] Developed a plan for monitoring legislative changes.
Long-Tail Queries: Questions and Answers
What are the new requirements for beneficiary disclosure in the EU?
Expansion of UBO identification criteria, reporting of changes within 28 days and at least annual verification of data (AMLR, from 10 July 2027), automation of submission and monitoring of information, tightening of sanctions for violations.
How to update beneficial owner data in the automated register?
Via the national or integrated corporate platform, providing up-to-date documents and confirmation of the ownership structure.
What are the consequences for concealing beneficiary information in a European company?
Fines under national law (in the Czech Republic, up to CZK 500,000), a ban on paying out profits to an unregistered beneficial owner, court prohibitions on operations, and account blockages.
How does the automation of the UBO register affect business in Europe?
Reduces compliance costs, accelerates processes, but requires a high level of digital maturity and data security.
What documents are needed for ultimate beneficial owner identification?
Passport, address proof, ownership documents, corporate resolutions confirming control.
To obtain relevant regulations and official clarifications, I recommend using resources from the European Commission, national regulators, and professional associations.
COREDO's experience shows: timely adaptation to the new UBO and AML requirements is not only a question of legality but also a strategic advantage in international business. A reliable corporate governance structure, compliance digitalization, and business owner transparency become key factors for sustainable growth and partner trust.