{ "meta": { "version": "v0", "buildDate": "2026-06-22", "scope": "Public-access POLICY status of national beneficial-ownership registers — a record of state behavior (which registers are open, gated, or closed), with zero individual personal data. Triggered by the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20) that struck down general-public access to EU beneficial-ownership registers.", "jurisdictionCount": 62, "byStatus": { "partial-or-other": 11, "legitimate-interest-gated": 24, "never-public": 16, "public-open": 9, "closed-post-cjeu": 2 } }, "jurisdictions": [ { "jurisdiction": "Australia", "iso2": "AU", "registerName": "Proposed Commonwealth beneficial-ownership register for unlisted companies (not yet established)", "accessStatus": "partial-or-other", "statusSummary": "Australia has no operational beneficial-ownership register as of 2026. The Government (announced 2025) has committed to proceed directly to a public, Commonwealth-operated central register of beneficial ownership for unlisted companies (dropping the earlier idea of company-held public registers), but it is not yet in force. ASIC received $207m additional funding (2025-26 to 2026-27) to stabilise/uplift the companies register first; detailed policy development and public consultation on the BO register are slated to begin from early 2027, with implementation thereafter. Because the public register is committed but NOT yet in force, this is recorded as partial-or-other, not public-open. CJEU has no application (Australia is outside the EU).", "legalBasis": "No enacted BO-register statute yet. Policy commitment via Treasury/Government announcements (2024-2025) for a centralised public register for unlisted entities; preceded by registry modernisation under the Treasury Laws Amendment (Registries Modernisation) framework and 2025 registry stabilisation/uplift work. Detailed legislation and access rules to follow from 2027.", "keyDate": "2025-01-01", "sourceUrl": "https://ministers.treasury.gov.au/ministers/andrew-leigh-2025/media-releases/improving-transparency-true-owners-companies", "sourceTitle": "Australian Treasury (Assistant Minister Andrew Leigh) — Improving transparency of the true owners of companies", "confidence": "high" }, { "jurisdiction": "Austria", "iso2": "AT", "registerName": "Register of Beneficial Owners (Register der wirtschaftlichen Eigentuemer, WiEReG)", "accessStatus": "legitimate-interest-gated", "statusSummary": "General public access was suspended immediately after the 22 Nov 2022 CJEU judgment; the register is now accessible to obliged entities, authorities and, following the 1 October 2025 WiEReG amendment, to persons with a legitimate interest (journalists, academics, business counterparties, third-country obliged entities) consistent with AMLD6.", "legalBasis": "Beneficial Owners Register Act (WiEReG) as amended 1 Oct 2025, implementing AMLD6 legitimate-interest access following the 22 Nov 2022 CJEU judgment in joined cases C-37/20 and C-601/20.", "keyDate": "2025-10-01", "sourceUrl": "https://www.transparency.org/en/news/countdown-to-new-eu-beneficial-ownership-rules", "sourceTitle": "Countdown to new EU beneficial ownership rules: Testing progress on access to registers - Transparency International", "confidence": "high" }, { "jurisdiction": "Bahamas", "iso2": "BS", "registerName": "Register of Beneficial Ownership (secure search system established by the Attorney-General as Competent Authority)", "accessStatus": "never-public", "statusSummary": "The Bahamas operates a secure search system, established by the Office of the Attorney-General as Competent Authority, over beneficial-ownership databases held by registered agents. As of 2026 the register is not accessible to the public; searches may only be conducted by designated officers on behalf of competent authorities (e.g. the Attorney-General, FIU, Central Bank, Securities Commission, Compliance Commission, Insurance Commission). A 2025 amendment updated the regime but did not make the register public.", "legalBasis": "Register of Beneficial Ownership Act, 2018 (No. 38 of 2018), as amended by the Register of Beneficial Ownership (Amendment) Act, 2025", "keyDate": "2018-12-01", "sourceUrl": "https://laws.bahamas.gov.bs/cms/images/LEGISLATION/PRINCIPAL/2018/2018-0038/2018-0038_1.pdf", "sourceTitle": "Register of Beneficial Ownership Act, 2018 (No. 38 of 2018) - Laws of The Bahamas", "confidence": "high" }, { "jurisdiction": "Barbados", "iso2": "BB", "registerName": "No public central beneficial-ownership register; beneficial-ownership records maintained by entities and accessible to the Registrar (CAIPO) and competent authorities", "accessStatus": "never-public", "statusSummary": "Barbados requires legal persons to identify, verify and maintain up-to-date beneficial-ownership information at their registered office. As of 2026 there is no publicly accessible central beneficial-ownership register; the information is provided to the Registrar of Corporate Affairs (CAIPO) or competent authorities on request rather than published.", "legalBasis": "Companies Act, Cap. 308 (beneficial-ownership provisions) with CAIPO guidelines; administered by the Corporate Affairs and Intellectual Property Office (CAIPO)", "keyDate": "2021-07-01", "sourceUrl": "https://2021-2025.state.gov/reports/2024-investment-climate-statements/barbados/", "sourceTitle": "2024 Investment Climate Statements: Barbados - U.S. Department of State", "confidence": "medium" }, { "jurisdiction": "Belgium", "iso2": "BE", "registerName": "UBO Register (Register van uiteindelijke begunstigden / Registre des beneficiaires effectifs)", "accessStatus": "legitimate-interest-gated", "statusSummary": "Public access has been blocked since the 22 Nov 2022 CJEU judgment; the register is now accessible only to authorities, obliged entities and private individuals or legal persons who can demonstrate a legitimate interest (e.g. AML/CFT-related work, presumed by the Royal Decree of 8 Feb 2023), aligned with AMLD6.", "legalBasis": "Royal Decree of 8 February 2023 (legitimate-interest access) implementing AMLD6, following the 22 Nov 2022 CJEU judgment in joined cases C-37/20 and C-601/20.", "keyDate": "2023-02-08", "sourceUrl": "https://www.pwclegal.be/en/news/access-to-the-ubo-register-limited-to-persons-with-a-legitimate-.html", "sourceTitle": "Access to the UBO register limited to persons with a legitimate interest - PwC Legal Belgium", "confidence": "high" }, { "jurisdiction": "Belize", "iso2": "BZ", "registerName": "Online Beneficial Ownership Registry (within the Online Business Registry System / OBRS), administered by the Belize Companies and Corporate Affairs Registry (BCCAR)", "accessStatus": "never-public", "statusSummary": "Belize collects beneficial-ownership information through the BCCAR's Online Business Registry System (OBRS), filed by registered agents from within Belize. As of 2026 the information is not accessible to the general public; access is restricted to the registered agent and government competent authorities established by law.", "legalBasis": "Belize Companies Act No. 11 of 2022 and the Belize Companies (Amendment) Act, 2023; OBRS administered by BCCAR", "keyDate": "2023-01-01", "sourceUrl": "https://bccar.bz/guidelines-on-beneficial-ownership-information-for-legal-persons-and-legal-arrangements/", "sourceTitle": "Guidelines on Beneficial Ownership Information for Legal Persons and Legal Arrangements - Belize Companies and Corporate Affairs Registry", "confidence": "high" }, { "jurisdiction": "Bermuda", "iso2": "BM", "registerName": "Central Register of Beneficial Ownership (maintained by the Registrar of Companies; Bermuda Monetary Authority as a competent authority)", "accessStatus": "partial-or-other", "statusSummary": "As of mid-2026 the Bermuda beneficial ownership register is NOT publicly accessible. Access is currently restricted to competent authorities (including the Bermuda Monetary Authority) and AML/ATF obliged entities (financial institutions and DNFBPs) conducting customer due diligence and discrepancy reporting; recipients are prohibited from onward disclosure. Bermuda committed (2024 JMC communique) to deliver 'legitimate interest' access by June 2025 or earlier, but its consultation now targets Q3 2026 for that legitimate-interest phase, which had not yet entered into force as of mid-2026 (Transparency International UK cited Bermuda for the delay). As a UK Overseas Territory (non-EU), the CJEU 'closed' label does not apply; Bermuda's earlier 2020 pledge of a fully public register has not been implemented and current policy follows a restricted/legitimate-interest model rather than full public access.", "legalBasis": "Beneficial Ownership Act 2025 (Royal Assent 28 September 2025; substantively operative on/around 3 November 2025; Registrar enforcement of filing requirements from 1 June 2026). Legitimate-interest access phase pledged via the 2024 Joint Ministerial Council communique, targeted for Q3 2026, not yet in force.", "keyDate": "2025-11-03", "sourceUrl": "https://www.conyers.com/publications/view/bermuda-new-beneficial-ownership-framework/", "sourceTitle": "Bermuda: New Beneficial Ownership Framework - Conyers", "confidence": "high" }, { "jurisdiction": "British Virgin Islands", "iso2": "VG", "registerName": "Register of Beneficial Ownership (for BVI Business Companies and Limited Partnerships), accessed via the VIRRGIN platform / Registrar of Corporate Affairs", "accessStatus": "legitimate-interest-gated", "statusSummary": "The BVI does not operate a fully public beneficial ownership register. The Government of the Virgin Islands introduced a Policy on Rights of Access to the Register of Beneficial Ownership on 23 June 2025, allowing access to those who demonstrate a legitimate interest (e.g. investigating money laundering/terrorist or proliferation financing, or fulfilling AML/CFT/CPF obligations), alongside competent-authority and obliged-entity access. A nine-month transitional period ran from 1 July 2025, with legitimate-interest access becoming fully operational on 1 April 2026. Requests go through the VIRRGIN platform with a purpose statement, a confidentiality declaration and a US$75 fee; subject companies may object within five business days and beneficial owners may seek protection exemptions. As a UK Overseas Territory (non-EU), the CJEU 'closed' label does not apply; a fully public register remains a UK-pressed aspiration, not the current law.", "legalBasis": "BVI Business Companies Act and the Beneficial Ownership regime (BOSS regime predecessor superseded); Policy on Rights of Access to the Register of Beneficial Ownership (June 2025) and implementing legislation operational from 1 April 2026.", "keyDate": "2026-04-01", "sourceUrl": "https://bvi.gov.vg/sites/default/files/policy_on_rights_of_access_to_the_register_of_beneficial_ownership_-_june_2025.pdf", "sourceTitle": "Policy on Rights of Access to the Register of Beneficial Ownership - Government of the Virgin Islands (June 2025)", "confidence": "high" }, { "jurisdiction": "Bulgaria", "iso2": "BG", "registerName": "Beneficial ownership data within the Commercial Register and Register of Non-Profit Legal Entities (Registry Agency / BULSTAT)", "accessStatus": "public-open", "statusSummary": "Bulgaria did not close its register after the CJEU ruling; beneficial ownership data remains publicly accessible online through the Registry Agency's commercial register portal (basic data such as name, nationality, country of residence and nature of control freely viewable; full documents require qualified e-signature or a residents-only PIN). A June 2025 reform added a legitimate-interest access layer but did not remove public access.", "legalBasis": "Measures Against Money Laundering Act (UBO data held in the Commercial Register); register kept open despite the 22 Nov 2022 CJEU judgment; Decree no. 92 of 4 June 2025 adds legitimate-interest access under AMLD6.", "keyDate": "2025-06-04", "sourceUrl": "https://www.kyckr.com/blog/eu-ubo-register-access-for-obliged-entities-2025", "sourceTitle": "EU UBO Registry Access for Obliged Entities (2026 Guide) - Kyckr", "confidence": "medium" }, { "jurisdiction": "Canada", "iso2": "CA", "registerName": "Federal Register of Individuals with Significant Control (ISC), Corporations Canada (CBCA companies)", "accessStatus": "public-open", "statusSummary": "Corporations Canada launched a free public search of beneficial-ownership (ISC) information for federally incorporated CBCA companies in January 2024; anyone can query it online. Coverage is federal-only (provincial/territorial corporations are separate), and structured bulk data and API access are not yet available. Canada is not an EU jurisdiction; the CJEU judgment does not apply.", "legalBasis": "Bill C-42, An Act to amend the Canada Business Corporations Act (royal assent 2 Nov 2023), with the public-access amendments in force by order in council 22 Jan 2024.", "keyDate": "2024-01-22", "sourceUrl": "https://www.openownership.org/en/news/canada-passes-law-to-create-public-beneficial-ownership-register/", "sourceTitle": "Canada passes law to create public beneficial ownership register | Open Ownership", "confidence": "medium" }, { "jurisdiction": "Cayman Islands", "iso2": "KY", "registerName": "Beneficial Ownership Register (administered by the Registrar of Companies / General Registry under the Competent Authority)", "accessStatus": "legitimate-interest-gated", "statusSummary": "The Cayman Islands beneficial ownership register is not open to the general public. Access by members of the public is granted only on a demonstrated legitimate-interest basis (e.g. journalists, civil society organisations, financial-crime investigators, prospective business counterparties), in addition to the standard access by competent authorities and AML obliged entities for CDD. In March 2026 the government publicly reaffirmed it will NOT move to a fully open, public-facing 'Google-style' register, citing constitutional/privacy concerns and the EU CJEU privacy reasoning, despite UK pressure. The 2026 amendment regulations only adjusted access fees (single search raised to US$75; new US$250 annual multi-search administrative fee), keeping the legitimate-interest gate in place. As a non-EU jurisdiction the CJEU 'closed' label does not apply.", "legalBasis": "Beneficial Ownership Transparency Act, 2023 (and amendments); Beneficial Ownership Transparency (Legitimate Interest Access) Regulations, as amended by the Beneficial Ownership Transparency (Legitimate Interest Access) (Amendment) Regulations, 2026.", "keyDate": "2026-03-18", "sourceUrl": "https://www.caymancompass.com/2026/03/13/cayman-unified-on-legitimate-interests-for-beneficial-ownership/", "sourceTitle": "Cayman unified on legitimate interests for beneficial ownership - Cayman Compass (13 March 2026)", "confidence": "high" }, { "jurisdiction": "Cook Islands", "iso2": "CK", "registerName": "No public register; BO information held by registered/administering trustee companies under Financial Supervisory Commission oversight", "accessStatus": "never-public", "statusSummary": "The Cook Islands does not maintain a publicly accessible beneficial ownership register. The Financial Supervisory Commission (FSC) Registrar can confirm only basic entity details (name, registration number, registration date, registered office, administering trustee company); beneficial ownership information is held by licensed registered/trustee companies and is not publicly searchable. Such information is available to competent authorities under the applicable legal framework.", "legalBasis": "International Companies Act 1981-82; AML/CFT and trustee-company supervisory framework", "keyDate": "", "sourceUrl": "https://www.fsc.gov.ck/public/content.aspx?cn=Registry", "sourceTitle": "Financial Supervisory Commission - Cook Islands (Registry)", "confidence": "high" }, { "jurisdiction": "Croatia", "iso2": "HR", "registerName": "Register of Beneficial Owners (Registar stvarnih vlasnika, RSV), administered by FINA", "accessStatus": "partial-or-other", "statusSummary": "Following the 22 Nov 2022 CJEU ruling Croatia restricted access: the register is nominally public but online viewing requires authentication via the national NIAS / e-Citizen system, available in practice only to Croatian citizens, residents and entities (or holders of a compatible eIDAS e-ID), so general/foreign public access is effectively gated rather than open. Croatia missed the July 2025 AMLD6 deadline and has not yet implemented a formal legitimate-interest access scheme.", "legalBasis": "Act on the Prevention of Money Laundering and Terrorist Financing (register administered by FINA); national e-ID (NIAS) authentication gating adopted after the 22 Nov 2022 CJEU judgment in joined cases C-37/20 and C-601/20; AMLD6 legitimate-interest transposition still pending as of 2026.", "keyDate": "2022-11-22", "sourceUrl": "https://taxjustice.net/2023/07/13/split-among-eu-countries-over-beneficial-ownership-ruling-mirrors-rankings-on-financial-secrecy-index/", "sourceTitle": "Split among EU countries over beneficial ownership ruling mirrors rankings on Financial Secrecy Index - Tax Justice Network", "confidence": "medium" }, { "jurisdiction": "Cyprus", "iso2": "CY", "registerName": "Cyprus Register of Beneficial Owners (Department of Registrar of Companies and Intellectual Property)", "accessStatus": "closed-post-cjeu", "statusSummary": "Public access to the UBO register has been suspended since 3 January 2023. Cyprus has not established a functioning legitimate-interest channel and has in practice denied access even to journalists and CSOs demonstrating legitimate interest; AMLD6 legitimate-interest operational rules remain to be transposed (deadline July 2026).", "legalBasis": "Suspension caused by the CJEU judgment of 22 November 2022 in joined cases C-37/20 and C-601/20, which invalidated the AMLD5 public-access provision; AMLD6 (Directive (EU) 2024/1640) legitimate-interest access not yet operational.", "keyDate": "2023-01-03", "sourceUrl": "https://www.openownership.org/en/map/country/cyprus/", "sourceTitle": "Cyprus | Open Ownership", "confidence": "medium" }, { "jurisdiction": "Czechia", "iso2": "CZ", "registerName": "Evidence skutecnych majitelu (Register of Beneficial Owners), Czech Ministry of Justice", "accessStatus": "legitimate-interest-gated", "statusSummary": "The public portion of the register was taken offline on 17 December 2025. Access is now limited to public authorities, AML-obliged entities, other privileged entities, and persons who can demonstrate a legitimate interest. (Earlier in 2025 the register had still been publicly accessible, so any 'public-open' designation for 2026 would be outdated.)", "legalBasis": "Czech Supreme Court and Supreme Administrative Court rulings (2025) holding that unrestricted public access breaches the right to privacy/data protection under the EU Charter, aligned with the CJEU judgment of 22 November 2022 (joined cases C-37/20 and C-601/20); transition toward AMLD6 (Directive (EU) 2024/1640).", "keyDate": "2025-12-17", "sourceUrl": "https://danovky.cz/en/news/detail/1757", "sourceTitle": "Register of beneficial owners publicly inaccessible from 17 December 2025 | KPMG Czech Republic", "confidence": "high" }, { "jurisdiction": "Denmark", "iso2": "DK", "registerName": "Central Business Register (CVR), Danish Business Authority", "accessStatus": "legitimate-interest-gated", "statusSummary": "Since 1 September 2025 Denmark provides beneficial ownership information only to competent authorities, AML-obliged entities, and persons with a legitimate interest (including journalists, CSOs and researchers). Eligible users access data via CVR.dk by logging in with MitID and submitting a solemn declaration confirming they meet the criteria; an API is also available.", "legalBasis": "Implements the CJEU judgment of 22 November 2022 (joined cases C-37/20 and C-601/20) via AMLD6 (Directive (EU) 2024/1640); replaced Denmark's prior open public-access model.", "keyDate": "2025-09-01", "sourceUrl": "https://www.mazantipulse.com/updates/restrictions-on-public-access-to-beneficial-ownership-information/", "sourceTitle": "Restrictions on Public Access to Beneficial Ownership Information - Mazanti Pulse", "confidence": "high" }, { "jurisdiction": "Estonia", "iso2": "EE", "registerName": "e-Business Register (e-Ariregister) Beneficial Owners Database, Centre of Registers and Information Systems (RIK)", "accessStatus": "legitimate-interest-gated", "statusSummary": "Public access to beneficial ownership data was restricted in 2025 following the CJEU ruling; the register reopened in January 2026 under a tiered model limited to competent authorities, AML-obliged entities, and parties demonstrating a legitimate interest. Further access-rule changes take effect 10 July 2026.", "legalBasis": "Restriction driven by the CJEU judgment of 22 November 2022 (joined cases C-37/20 and C-601/20) invalidating AMLD5 public access; reopened access tiers implement AMLD6 (Directive (EU) 2024/1640).", "keyDate": "2026-01", "sourceUrl": "https://www.openownership.org/en/map/country/estonia/", "sourceTitle": "Estonia | Open Ownership", "confidence": "high" }, { "jurisdiction": "Finland", "iso2": "FI", "registerName": "Beneficial Owners Register (Finnish Patent and Registration Office, PRH)", "accessStatus": "legitimate-interest-gated", "statusSummary": "Unrestricted public access ended after the 22 Nov 2022 CJEU ruling. Access is now granted to persons/entities demonstrating a legitimate interest, via both a general contract option with the PRH and case-by-case extract requests; obliged entities and authorities also have access. Transparency International's 2024-25 testing found Finland responds to legitimate-interest requests within a few days.", "legalBasis": "EU AML Directives (4th/5th AMLD) as constrained by the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20); transition to AMLD6 / Regulation (EU) 2024/1640 legitimate-interest regime; national Act on the Prevention of Money Laundering and Terrorist Financing (444/2017).", "keyDate": "2022-11", "sourceUrl": "https://www.openownership.org/en/map/country/finland/", "sourceTitle": "Finland | Open Ownership", "confidence": "high" }, { "jurisdiction": "France", "iso2": "FR", "registerName": "Registre des bénéficiaires effectifs (RBE), held by INPI", "accessStatus": "legitimate-interest-gated", "statusSummary": "General public access to the RBE was closed on 31 July 2024. Full register information is now available only to persons demonstrating a legitimate interest (validated by the courts) and to a defined list of authorized entities, including journalists and researchers working on financial transparency, plus AML professionals and competent authorities. Approved applicants receive an access certificate valid three years.", "legalBasis": "EU AML Directive 2024/1640 (AMLD6, 31 May 2024) following the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20); transposed by French Law No. 2025-391 (DDADUE5, 30 Apr 2025) and Decree No. 2026-310 (24 Apr 2026).", "keyDate": "2024-07-31", "sourceUrl": "https://entreprendre.service-public.gouv.fr/actualites/A17554?lang=en", "sourceTitle": "Life of the company - New conditions for access to the Beneficial Owners Register | Service-Public Entreprendre", "confidence": "high" }, { "jurisdiction": "Germany", "iso2": "DE", "registerName": "Transparenzregister (German Transparency Register)", "accessStatus": "legitimate-interest-gated", "statusSummary": "Open public access to the Transparenzregister was struck down by the 22 Nov 2022 CJEU judgment. Access now requires demonstrating a legitimate interest, assessed case-by-case by the registry authority (Bundesanzeiger Verlag); the authority's Jan 2023 guidance presumes legitimate interest for self-inspection and for journalists/NGOs researching money laundering or terrorist financing. Transparency International's 2024-25 testing confirmed Germany grants legitimate-interest access.", "legalBasis": "Geldwäschegesetz (GwG, German Anti-Money Laundering Act) applied in light of the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20); transition to the AMLD6 / Regulation (EU) 2024/1640 legitimate-interest regime.", "keyDate": "2022-11-22", "sourceUrl": "https://www.transparency.org/en/news/countdown-to-new-eu-beneficial-ownership-rules", "sourceTitle": "Countdown to new EU beneficial ownership rules: Testing progress on legitimate interest access | Transparency International", "confidence": "high" }, { "jurisdiction": "Gibraltar", "iso2": "GI", "registerName": "Gibraltar Register of Ultimate Beneficial Owners, Nominators and Appointors (UBO Register)", "accessStatus": "public-open", "statusSummary": "UK Overseas Territory, not an EU member state (post-Brexit), so the 22 Nov 2022 CJEU judgment does not bind it and 'closed-post-cjeu' does not apply. Gibraltar has maintained a publicly accessible UBO register since 2020 and is one of only three UK Overseas Territories (with Montserrat and St Helena) operating a fully public beneficial-ownership register — it expanded rather than restricted access after the CJEU ruling. A free public search portal (ubosearch.egov.gi) is live and open to anyone without a legitimate-interest test; per a Gibraltar Government press release of 23 Feb 2026, the enhanced register 'will shortly become fully operational and accessible free of charge to any individual wishing to conduct a search.' Transparency International has publicly praised Gibraltar's public-register approach.", "legalBasis": "Register of Ultimate Beneficial Owners, Nominators and Appointors Regulations 2017 (originating from EU AMLD transposition while Gibraltar was within the EU legal order pre-Brexit); all Gibraltar legal persons must collect, maintain and report UBO information; free public-search access reaffirmed by the Gibraltar Government on 23 Feb 2026 in line with its commitment to the UK Government.", "keyDate": "2026-02-23", "sourceUrl": "https://www.gibraltar.gov.gi/press-releases/ultimate-beneficial-ownership-register-1112026-11724", "sourceTitle": "Ultimate Beneficial Ownership Register — Press Release 111/2026, Government of Gibraltar (23 Feb 2026); corroborated by the live public portal ubosearch.egov.gi and GBC reporting on Transparency International's endorsement", "confidence": "high" }, { "jurisdiction": "Greece", "iso2": "GR", "registerName": "Central Register of Beneficial Owners (Kentriko Mitroo Pragmatikon Dikaiouchon)", "accessStatus": "legitimate-interest-gated", "statusSummary": "General-public access was suspended from 1 December 2022 following the 22 Nov 2022 CJEU ruling. Access is retained for obliged entities (banks, law firms, accountants) for due-diligence purposes (subject to an annual fee) and for persons/organizations demonstrating a legitimate interest; competent authorities also retain access. Greece is now moving to the AMLD6 / Regulation (EU) 2024/1640 legitimate-interest model.", "legalBasis": "Law 4557/2018 (transposing the EU AML Directives) as constrained by the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20); transition to Directive (EU) 2024/1640 (AMLD6) legitimate-interest regime.", "keyDate": "2022-12-01", "sourceUrl": "https://www.legalink.ch/groups/newsletter-articles/temporary-suspension-in-greece-of-the-access-to-the-beneficial-owners-register-for-the-general/3032/", "sourceTitle": "Temporary suspension in Greece of access to the Beneficial Owners Register for the general public following CJEU Judgement of 22 November 2022 | Legalink", "confidence": "high" }, { "jurisdiction": "Guernsey", "iso2": "GG", "registerName": "Guernsey Register of Beneficial Ownership of Legal Persons (Guernsey Registry)", "accessStatus": "partial-or-other", "statusSummary": "Crown Dependency, not an EU state, so the 22 Nov 2022 CJEU judgment does not legally bind it. There is NO general public access to the register. Obliged-entity access (Bailiwick supervised persons conducting CDD for a lawful purpose) has been available since August 2025. A separate, broader 'legitimate interest' access route (for parties such as journalists and civil-society/NGO actors fighting financial crime, via a case-by-case secure application to the Guernsey Registry) is only at the proposal/consultation stage as of mid-2026 and is NOT yet enacted or operational. Labelled partial-or-other (not legitimate-interest-gated) because legitimate-interest access is not yet in force; current access is restricted to authorities and obliged entities.", "legalBasis": "Beneficial Ownership of Legal Persons (Guernsey) Law 2017 (register established); obliged-entity access framework operational since Aug 2025; legitimate-interest access proposed via a public consultation the States of Guernsey published 27 Feb 2026 (closed 10 Apr 2026), timing aligned with the EU AMLD6 reference deadline but not yet legislated.", "keyDate": "2026-02-27", "sourceUrl": "https://www.transparency.org.uk/publications/providing-legitimate-interest-access-guernseys-beneficial-ownership-data", "sourceTitle": "Providing legitimate interest access to Guernsey's beneficial ownership data — Transparency International UK; corroborated by States of Guernsey consultation (gov.gg) and Walkers Global briefing (Feb 2026)", "confidence": "high" }, { "jurisdiction": "Hong Kong", "iso2": "HK", "registerName": "Significant Controllers Register (SCR)", "accessStatus": "never-public", "statusSummary": "Hong Kong has no public beneficial-ownership register. Companies incorporated in Hong Kong (with exemptions for HKEX-listed companies) must keep a Significant Controllers Register at their registered office or a prescribed place and designate a representative to assist law enforcement. The SCR is not delivered to the Companies Registry for public registration and is not open to the general public; it is open for inspection only by law enforcement officers (Companies Registry, Hong Kong Police, ICAC, HKMA, SFC, etc.) on demand, and by the significant controllers themselves. CJEU has no application (Hong Kong is outside the EU).", "legalBasis": "Companies (Amendment) Ordinance 2018, inserting the Significant Controllers Register regime into the Companies Ordinance (Cap. 622), Part 12 Division 2A; commenced 1 March 2018. Inspection limited to listed law enforcement officers.", "keyDate": "2018-03-01", "sourceUrl": "https://www.cr.gov.hk/en/legislation/scr/overview.htm", "sourceTitle": "Hong Kong Companies Registry — Significant Controllers Register: Overview", "confidence": "high" }, { "jurisdiction": "Hungary", "iso2": "HU", "registerName": "Central Register of Ultimate Beneficial Owners (Afad / UBO register, maintained by NAV via BISZ)", "accessStatus": "legitimate-interest-gated", "statusSummary": "No general public search portal. Competent authorities, AML-obliged service providers and the entity itself have access; third parties may obtain data only by demonstrating a documented legitimate interest in combating money laundering/terrorist financing and paying a fee. In practice access is granted very restrictively (Transparency International was refused in 2025).", "legalBasis": "Act XLIII of 2021 (Afad Act) and Act LIII of 2017 (AML Act). Unconditional public access was cut off in 2023 following the 22 Nov 2022 CJEU judgment in joined cases C-37/20 and C-601/20; access is now legitimate-interest based, consistent with AMLD6.", "keyDate": "2023", "sourceUrl": "https://www.noerr.com/en/insights/hungarian-central-register-of-ultimate-beneficial-ownership", "sourceTitle": "Hungarian Central Register of Ultimate Beneficial Ownership (Noerr)", "confidence": "medium" }, { "jurisdiction": "India", "iso2": "IN", "registerName": "Register of Significant Beneficial Owners (SBO) / Form BEN-2 filings with the Registrar of Companies, Ministry of Corporate Affairs (MCA)", "accessStatus": "partial-or-other", "statusSummary": "India requires companies to maintain a register of significant beneficial owners (Form BEN-3) and file SBO details with the Registrar of Companies via Form BEN-2. There is no central, freely searchable public beneficial-ownership register; Open Ownership records that structured BO data is not publicly available and there is no API. BEN-2 is an eForm filed with the MCA and individual company filings can be inspected through the MCA 'View Public Documents' service on payment of a per-company fee, so limited per-company paid access exists rather than open public access.", "legalBasis": "Companies (Significant Beneficial Owners) Rules, 2018, under Section 90 of the Companies Act, 2013 (amended by the Companies (SBO) Amendment Rules, 2024)", "keyDate": "2018-02-08", "sourceUrl": "https://www.openownership.org/en/map/country/india/", "sourceTitle": "Open Ownership — Worldwide implementation map: India", "confidence": "medium" }, { "jurisdiction": "Ireland", "iso2": "IE", "registerName": "Central Register of Beneficial Ownership of Companies and Industrial & Provident Societies (RBO)", "accessStatus": "legitimate-interest-gated", "statusSummary": "General public access ended after the November 2022 CJEU ruling and was restricted in Irish law in June 2023. Designated persons (banks, lawyers, accountants) and competent authorities retain access; members of the public must now demonstrate a legitimate interest, assessed case-by-case on paper, and reportedly very few/no such requests have been approved.", "legalBasis": "European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) (Amendment) Regulations 2023 (S.I. No. 308 of 2023), implementing the legitimate-interest model after the 22 Nov 2022 CJEU judgment in joined cases C-37/20 and C-601/20.", "keyDate": "2023-06", "sourceUrl": "https://www.pinsentmasons.com/out-law/news/ireland-limits-public-access-to-register-of-beneficial-owners", "sourceTitle": "Ireland limits public access to register of beneficial owners (Pinsent Masons / Out-Law)", "confidence": "high" }, { "jurisdiction": "Isle of Man", "iso2": "IM", "registerName": "Isle of Man Database of Beneficial Ownership (Companies Registry, Department for Enterprise)", "accessStatus": "partial-or-other", "statusSummary": "Crown Dependency, not an EU state, so the 22 Nov 2022 CJEU judgment does not legally bind it. There is NO general public access. Access was historically limited to competent authorities; from 1 January 2025 'obliged entities' (persons subject to the AML/CFT Code or the Gambling AML/CFT Code) may also access the Database for customer due diligence. A 'legitimate interest' access route (application-based, assessed case-by-case by the Central Registry, for preventing/detecting/investigating ML/TF/proliferation financing) is in public consultation (opened 5 May 2026, closes 30 June 2026) and is NOT yet enacted. Labelled partial-or-other because legitimate-interest access is not yet in force; current access is authorities plus obliged entities only.", "legalBasis": "Beneficial Ownership Act 2017 (AT 3 of 2017) establishes and governs the Database; obliged-entity access enabled by the Beneficial Ownership (Obliged Entities Access) Order 2024 (effective 1 Jan 2025); legitimate-interest access only proposed via the May 2026 consultation, consistent with the Dec 2023 joint Crown Dependencies commitment aligned to EU AMLD6.", "keyDate": "2025-01-01", "sourceUrl": "https://www.gov.im/news/2024/dec/18/isle-of-man-steps-up-access-to-beneficial-ownership-register/", "sourceTitle": "Isle of Man steps up access to beneficial ownership register — Isle of Man Government (Dec 2024); corroborated by IOMFSA May 2026 legitimate-interest consultation and Beneficial Ownership Act 2017", "confidence": "high" }, { "jurisdiction": "Italy", "iso2": "IT", "registerName": "Registro dei titolari effettivi (Beneficial Owners' Register), held within the Registro delle Imprese", "accessStatus": "partial-or-other", "statusSummary": "Filing obligations are in force but public/consultation access remains suspended as of 2026 (data filed but not consultable). National authorities retain access; consultation by obliged entities, accreditation and third-party access requests are frozen. A tiered legitimate-interest access model has been legislated but had not become operational. The proximate cause was Italian administrative-court rulings (TAR Lazio Dec 2023; Council of State 17 May 2024), grounded in the same EU privacy concerns as the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20).", "legalBasis": "Ministerial Decree 55/2022; suspension via TAR Lazio (Dec 2023) and Consiglio di Stato (17 May 2024) orders; reform/tiered-access framework (incl. Legislative Decree 210/2025) implementing AMLD6 not yet operational. Underlying driver: 22 Nov 2022 CJEU judgment, C-37/20 and C-601/20.", "keyDate": "2024-05-17", "sourceUrl": "https://www.lcalex.it/en/italys-beneficial-ownership-register-the-implications-of-the-cjeu-judgment-of-21-may-2026", "sourceTitle": "Italy's Beneficial Ownership Register: the Implications of the CJEU Judgment of 21 May 2026 (LCA Studio Legale)", "confidence": "medium" }, { "jurisdiction": "Jersey", "iso2": "JE", "registerName": "Register of beneficial ownership / Obliged Entity Beneficial Owner (OEBO) register (maintained by the Jersey Financial Services Commission Registry)", "accessStatus": "partial-or-other", "statusSummary": "Jersey's beneficial ownership register is NOT open to the general public. Jersey has concluded that unlimited public access would be incompatible with the ECHR and domestic law, and has refocused on restricted access. Since 24 February 2025, obliged entities ('relevant persons') and their representatives can search the Obliged Entity Beneficial Owner (OEBO) register via myJFSC strictly to perform customer due diligence; the information may not be used for any other purpose. A separate legitimate-interest access channel (for non-Jersey obliged entities, journalists, civil society and others demonstrating a legitimate interest in preventing/investigating ML/TF/PF) was put to public consultation from October 2025; that consultation closed on 30 January 2026 and, as of mid-2026, legitimate-interest access had not yet been implemented. As a Crown Dependency (non-EU), the CJEU 'closed' label does not apply.", "legalBasis": "Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 (DPI Law), Articles 8A and 8B (obliged-entity access and permitted disclosures), together with the Money Laundering (Jersey) Order 2008 (which establishes the CDD obligations justifying access). Legitimate-interest access still under consultation/not yet enacted.", "keyDate": "2025-02-24", "sourceUrl": "https://www.jerseyfsc.org/registry/beneficial-ownership-information/guidance-on-evidence-required-to-prove-legitimate-search-of-the-obliged-entity-beneficial-owner-register/", "sourceTitle": "Guidance on evidence required to prove legitimate search of the Obliged Entity Beneficial Owner Register - Jersey Financial Services Commission", "confidence": "high" }, { "jurisdiction": "Latvia", "iso2": "LV", "registerName": "Register of Enterprises (Uznemumu registrs / UR) beneficial owners (patiesa labuma guvejs) data", "accessStatus": "public-open", "statusSummary": "Latvia kept its beneficial-ownership data publicly available to all members of society after the CJEU ruling. Basic UBO information (name, shareholding) is freely searchable via the Enterprise Register portal and is also available via API and re-users; more detailed documents may require an account. It is one of the few EU states retaining open public access.", "legalBasis": "Cabinet of Ministers decision of 19 April 2024 to maintain public availability after assessing the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20); grounded in Latvia's Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing.", "keyDate": "2024-04-19", "sourceUrl": "https://www.tm.gov.lv/en/article/information-ultimate-beneficial-owners-will-continue-be-publicly-available-latvia", "sourceTitle": "Information on ultimate beneficial owners will continue to be publicly available in Latvia (Ministry of Justice of Latvia)", "confidence": "high" }, { "jurisdiction": "Liberia", "iso2": "LR", "registerName": "Liberia Beneficial Ownership Register (Liberia Business Registry)", "accessStatus": "public-open", "statusSummary": "Liberia operates a central beneficial ownership register administered by the Liberia Business Registry (LBR). Following BO regulations adopted in August 2023, the register launched in September 2023 with declarations opening from December 2023; a subset of beneficial ownership data is made publicly available online economy-wide, while fuller data is accessible to competent authorities and law enforcement. As of 2026 the public-facing portal is being rolled out.", "legalBasis": "Amendment to the Associations Law of Liberia (2020); Beneficial Ownership Regulation 2023", "keyDate": "2023-08-01", "sourceUrl": "https://eiti.org/news/liberia-launches-new-digital-beneficial-ownership-register", "sourceTitle": "Liberia launches a new digital beneficial ownership register (EITI)", "confidence": "medium" }, { "jurisdiction": "Liechtenstein", "iso2": "LI", "registerName": "Register of Beneficial Owners (Verzeichnis der wirtschaftlichen Eigentümer inländischer Rechtsträger, VwbP)", "accessStatus": "partial-or-other", "statusSummary": "Liechtenstein maintains a central electronic Register of Beneficial Owners (VwbP), operational since 1 April 2021. It is not publicly searchable; the national central register is accessible to the Office of Justice and competent Liechtenstein authorities for AML/CFT purposes. Limited information may be obtained through a separate disclosure procedure for parties able to demonstrate a legitimate interest.", "legalBasis": "Act on the Register of the Beneficial Owners of Legal Entities (Gesetz über das Verzeichnis wirtschaftlicher Eigentümer, VwbPG)", "keyDate": "2021-04-01", "sourceUrl": "https://www.openownership.org/en/map/country/liechtenstein/", "sourceTitle": "Open Ownership — Liechtenstein country profile (cross-checked with llv.li Office of Justice VwbP pages and EU e-Justice BOR factsheet)", "confidence": "high" }, { "jurisdiction": "Lithuania", "iso2": "LT", "registerName": "JANGIS (beneficial owners subsystem of JADIS), V. Registru centras", "accessStatus": "legitimate-interest-gated", "statusSummary": "Access to the JANGIS beneficial-ownership register is provided under a legitimate-interest model rather than open public access. Requesters can obtain extracts case-by-case or via a general contract, but general access seekers must complete a detailed legitimate-interest balance form; access routes are practically limited to persons/entities in Lithuania.", "legalBasis": "Post-22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20) removing the AMLD5 public-access mandate; access provided on a legitimate-interest basis, with AMLD6 (Directive (EU) 2024/1640) implementation due by 2026.", "keyDate": "2022-11", "sourceUrl": "https://www.transparency.org/en/news/countdown-to-new-eu-beneficial-ownership-rules", "sourceTitle": "Countdown to new EU beneficial ownership rules: Testing progress on legitimate interest access (Transparency International)", "confidence": "medium" }, { "jurisdiction": "Luxembourg", "iso2": "LU", "registerName": "Registre des beneficiaires effectifs (RBE), Luxembourg Business Registers", "accessStatus": "legitimate-interest-gated", "statusSummary": "Public access to the RBE was suspended immediately after the 22 Nov 2022 CJEU ruling and has since reopened on a restricted basis. Access is limited to national authorities, AML/CFT-obliged professionals, and persons demonstrating a legitimate interest (e.g. professional journalists, AML/CFT non-profits, and parties to a transaction).", "legalBasis": "22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20) invalidating AMLD5 public access; reopened under the Law of 27 January 2025 amending the Law of 13 January 2019 on the RBE (in force 1 February 2025).", "keyDate": "2025-02-01", "sourceUrl": "https://www.aoshearman.com/en/insights/luxembourg-adapts-its-rcs-and-rbe-legislations-after-cjeu-ruling", "sourceTitle": "Luxembourg adapts its RCS and RBE legislations after CJEU ruling (A&O Shearman)", "confidence": "high" }, { "jurisdiction": "Malta", "iso2": "MT", "registerName": "Register of Beneficial Owners, Malta Business Registry (MBR)", "accessStatus": "legitimate-interest-gated", "statusSummary": "After restricting public access following the 22 Nov 2022 CJEU ruling, Malta reopened the BO register on a legitimate-interest basis. Any natural or legal person who can demonstrate a legitimate interest in preventing/combating money laundering, predicate offences or terrorist financing may request access from the Registrar (one-time, application-based extracts).", "legalBasis": "22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20); reopened under Legal Notice 127 of 2025 (Companies Act (Register of Beneficial Owners) (Amendment) Regulations), first AMLD6 transposition phase implementing Art. 74 of Directive (EU) 2024/1640, in force 10 July 2025.", "keyDate": "2025-07-10", "sourceUrl": "https://shoulder.mt/malta-reopens-access-to-bo-registers-under-new-aml-framework/", "sourceTitle": "Malta Reopens Access to BO Registers Under New AML Framework (Shoulder.mt)", "confidence": "high" }, { "jurisdiction": "Marshall Islands", "iso2": "MH", "registerName": "No central public register; BO information held by the Registrar for Non-Resident Domestic Entities (Trust Company of the Marshall Islands) and registered agents", "accessStatus": "never-public", "statusSummary": "The Republic of the Marshall Islands does not maintain a publicly accessible beneficial ownership register. Beneficial ownership information for non-resident domestic entities is held by registered agents and the Registrar for NRDE (Trust Company of the Marshall Islands), and is disclosed only to the government and competent authorities under legal process or information-exchange obligations. There is no requirement to file officer, director, or shareholder names in any public registry.", "legalBasis": "Business Corporations Act (as amended 2019); Beneficial Ownership Regulations 2023", "keyDate": "2024-11-01", "sourceUrl": "https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Marshall-Islands-MER-November-2024.pdf.coredownload.inline.pdf", "sourceTitle": "Republic of the Marshall Islands Mutual Evaluation Report (FATF/APG, November 2024)", "confidence": "high" }, { "jurisdiction": "Mauritius", "iso2": "MU", "registerName": "Beneficial Ownership Register (kept by the Registrar of Companies, Corporate and Business Registration Department / CBRD)", "accessStatus": "never-public", "statusSummary": "Mauritius requires companies to file beneficial-ownership information with the Registrar of Companies (CBRD), which maintains a beneficial-ownership register. As of 2026 the register is not publicly accessible; it is available to competent authorities (including the FIU and law enforcement) and other prescribed public-sector authorities, with disclosure to third parties only on the owner's request, for an investigation, or by court order.", "legalBasis": "Companies Act 2001 (as amended in 2020) and the Financial Intelligence and Anti-Money Laundering Act (FIAMLA)", "keyDate": "2020-01-01", "sourceUrl": "https://www.openownership.org/en/map/country/mauritius/", "sourceTitle": "Mauritius | Open Ownership", "confidence": "high" }, { "jurisdiction": "Monaco", "iso2": "MC", "registerName": "Register of Beneficial Owners (Registre des bénéficiaires effectifs), annexed to the Trade and Industry Registry (RCI)", "accessStatus": "legitimate-interest-gated", "statusSummary": "Monaco maintains a Register of Beneficial Owners, annexed to the Trade and Industry Registry (RCI) and launched in 2018. Information is accessible to Monégasque public authorities, bodies subject to AML obligations, and any person able to justify a legitimate interest connected to the fight against money laundering. It is not a general-public open register.", "legalBasis": "Law No. 1.362 of 3 August 2009 (combating money laundering, terrorist financing and corruption), as amended by Law No. 1.462 of 28 June 2018 (Article 21 et seq.) and subsequently by Law No. 1.559 of 29 February 2024", "keyDate": "2018-06-28", "sourceUrl": "https://monentreprise.gouv.mc/en/themes/accounting-obligations-and-tax/legal-and-accounting-requirements/register-of-beneficial-owners", "sourceTitle": "Government of Monaco — Register of Beneficial Owners (monentreprise.gouv.mc), cross-checked with Open Ownership Monaco profile", "confidence": "high" }, { "jurisdiction": "Netherlands", "iso2": "NL", "registerName": "UBO register, Netherlands Chamber of Commerce (KVK)", "accessStatus": "legitimate-interest-gated", "statusSummary": "The Dutch UBO register closed to the public after the 22 Nov 2022 CJEU ruling and has since reopened on a restricted basis. Access is now available to competent authorities, Wwft/Wtt-obliged institutions for due diligence, and natural/legal persons who can demonstrate a legitimate interest. (Full self-service KVK access has implementation lag, with broader API/extract availability expected around Q2 2026, but the legitimate-interest legal regime is in force.)", "legalBasis": "22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20) ending AMLD5 public access; Amendment Act on Restricting Access to UBO Registers amending Articles 22, 22a and 28 of the Trade Register Act 2007 (Handelsregisterwet 2007), largely in force 15 July 2025.", "keyDate": "2025-07-15", "sourceUrl": "https://www.linklaters.com/en-us/knowledge/publications/alerts-newsletters-and-guides/2025/may/28/amending-act-restricted-access-dutch-ubo-registers-adopted", "sourceTitle": "Amending act restricted access Dutch UBO registers adopted (Linklaters)", "confidence": "high" }, { "jurisdiction": "New Zealand", "iso2": "NZ", "registerName": "Proposed beneficial-ownership register for companies and limited partnerships (not yet established)", "accessStatus": "partial-or-other", "statusSummary": "New Zealand has no beneficial-ownership register in force as of 2026. Draft legislation was consulted on in 2021-2022 but then stalled; in 2024 it was confirmed not under active consideration. On 20 December 2025 the Government revived the commitment as part of its Transnational Serious Organised Crime (TSOC) strategy, pledging to implement a BO register for companies and limited partnerships, overseen by MBIE, as a Priority 2 action within a five-year timeframe (implementation likely 2027 or later). Whether the register will be fully public and whether trusts will be included have not been finally decided. Because the register is only a renewed commitment and not yet established (and openness undecided), this is recorded as partial-or-other rather than public-open. CJEU has no application (New Zealand is outside the EU).", "legalBasis": "No enacted BO-register statute. Prior consultation on draft legislation (2021-2022) lapsed; renewed policy commitment via the Government's 20 December 2025 TSOC strategy, to be progressed by MBIE under the Companies Act 1993 / Limited Partnerships Act 2008 framework. Access model and scope (including trusts) to be determined.", "keyDate": "2025-12-20", "sourceUrl": "https://www.transparency.org.nz/blog/progress-on-beneficial-ownership-a-step-forward-but-a-long-road-remains", "sourceTitle": "Transparency International New Zealand — Progress on Beneficial Ownership: A Step Forward, But a Long Road Remains", "confidence": "high" }, { "jurisdiction": "Nigeria", "iso2": "NG", "registerName": "Open Central Register of Persons with Significant Control (PSC Register), Corporate Affairs Commission (CAC)", "accessStatus": "public-open", "statusSummary": "Nigeria's Corporate Affairs Commission launched an Open Central Register of Persons with Significant Control (PSC Register) on 25 May 2023, accessible to the general public free of charge at bor.cac.gov.ng. Open Ownership records that the register has full-economy scope, publishes structured data publicly and provides an API. Any member of the public can search the register to identify the persons with significant control of a company or LLP in Nigeria.", "legalBasis": "Companies and Allied Matters Act (CAMA) 2020 and the Persons with Significant Control Regulations 2022, implementing Nigeria's Open Government Partnership beneficial-ownership commitments", "keyDate": "2023-05-25", "sourceUrl": "https://www.openownership.org/en/map/country/nigeria/", "sourceTitle": "Open Ownership — Worldwide implementation map: Nigeria", "confidence": "high" }, { "jurisdiction": "Norway", "iso2": "NO", "registerName": "Register of Beneficial Owners (Register over reelle rettighetshavere), maintained by the Bronnoysund Register Centre", "accessStatus": "legitimate-interest-gated", "statusSummary": "Norway's Register of Beneficial Owners is NOT open to the general public. Following the 22 November 2022 CJEU ruling (Luxembourg Business Registers, on AMLD5), Norway did not provide for indiscriminate public access; instead access is restricted to defined categories: public authorities, media/journalists, civil society organisations, higher-education/research institutions, and AML-obliged entities (banks, real estate professionals, etc.). Non-authority users cannot search for natural persons or extract bulk data and access is API-only via national authentication gateways (Maskinporten/Samarbeidsportalen) with no open public search portal. This restricted, interest-based model is the legitimate-interest-gated pattern. Norway is an EEA (not EU) state, so the EU-only closed-post-cjeu label does not apply; it adopted a restricted-access regime rather than a full suspension.", "legalBasis": "Act on the Register of Beneficial Owners (Lov om register over reelle rettighetshavere, 1 March 2019; provisions entering into force from 2021) and the Anti-Money Laundering Act. Voluntary filing opened 1 October 2024; mandatory registration deadline 31 July 2025. Access categories (authorities, media, civil society, higher education, AML-obliged entities) set in the Act and regulations; further access expansion under government consultation.", "keyDate": "Mandatory registration deadline 31 July 2025 (voluntary filing opened 1 October 2024); access framework shaped after the 22 November 2022 CJEU ruling", "sourceUrl": "https://www.openownership.org/en/blog/a-brief-assessment-of-the-usability-of-norways-beneficial-ownership-register/", "sourceTitle": "OpenOwnership - A brief assessment of the usability of Norway's beneficial ownership register", "confidence": "high" }, { "jurisdiction": "Panama", "iso2": "PA", "registerName": "Private and Unique System of Beneficial Owners of Legal Persons (Sistema Privado y Unico de Registro de Beneficiarios Finales), Superintendency of Non-Financial Subjects (SSNF)", "accessStatus": "never-public", "statusSummary": "Not an EU state; the CJEU judgment is irrelevant. Panama operates an expressly private, confidential beneficial-ownership register with no public access. Access is restricted to competent Panamanian authorities, who must submit a formal, case-specific request tied to money laundering, terrorist financing or proliferation financing investigations (or international-treaty cooperation). The system is administered and held in custody by the Superintendency of Non-Financial Subjects (SSNF); the public cannot access the data and cannot compel disclosure through judicial or administrative actions. (A separate public fisheries-vessel UBO register exists but is distinct from the general company register.) OpenOwnership records its data as not publicly available.", "legalBasis": "Law No. 129 of 17 March 2020, which created the Private and Unique System of Beneficial Owners, mandating resident-agent filings to the SSNF while keeping the register private and accessible only to accredited competent authorities for defined purposes.", "keyDate": "2020-03-17", "sourceUrl": "https://www.openownership.org/en/map/country/panama/", "sourceTitle": "Panama — Open Ownership country profile ('Structured data publicly available: No'); corroborated by analyses of Law 129 of 2020 (Kraemer & Kraemer, Wolters Kluwer, Fabrega Molino)", "confidence": "high" }, { "jurisdiction": "Poland", "iso2": "PL", "registerName": "Centralny Rejestr Beneficjentów Rzeczywistych (CRBR) - Central Register of Beneficial Owners", "accessStatus": "public-open", "statusSummary": "As of 22 June 2026 the CRBR remains fully public-open: anyone can search beneficial-ownership data free online. A legitimate-interest gating regime (draft amendment to the AML Act) is scheduled to take effect on 1 July 2026, after which open access will end and only authorities, obliged entities and applicants demonstrating legitimate interest will have access.", "legalBasis": "Act on Counteracting Money Laundering and Terrorist Financing (AML Act); draft Ministry of Finance amendment implementing the EU AML package response to the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20). Restriction effective 1 July 2026.", "keyDate": "2026-07-01", "sourceUrl": "https://asbgroup.eu/en/news/the-central-register-of-beneficial-owners-crbr-is-no-longer-public-how-to-get-access/", "sourceTitle": "The Central Register of Beneficial Owners (CRBR) is no longer public - how to get access? | ASB Group", "confidence": "medium" }, { "jurisdiction": "Portugal", "iso2": "PT", "registerName": "Registo Central do Beneficiario Efetivo (RCBE) - Central Register of Beneficial Owners", "accessStatus": "legitimate-interest-gated", "statusSummary": "Previously public-open, the RCBE moved to a legitimate-interest access regime: access to beneficial-ownership information now requires demonstrating a legitimate interest (e.g. journalism, research, AML/due-diligence purposes), while authorities retain automatic access. This reopened/restricted model replaced unrestricted public access following the CJEU ruling.", "legalBasis": "Decree-Law No. 115/2025 of 27 October 2025, implementing Article 74 of EU Directive 2024/1640 (AMLD6), following the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20).", "keyDate": "2025-10-27", "sourceUrl": "https://schmidt-export.com/news/portugal-aligns-access-beneficial-ownership-register-eu-court-ruling-and-eu-directives", "sourceTitle": "Portugal aligns access to beneficial ownership register with EU Court Ruling and EU Directives | Schmidt & Schmidt", "confidence": "high" }, { "jurisdiction": "Romania", "iso2": "RO", "registerName": "Registrul Beneficiarilor Reali (RBR) - Register of Beneficial Owners, administered by ONRC (National Trade Register Office)", "accessStatus": "legitimate-interest-gated", "statusSummary": "Access is now restricted to natural or legal persons who can demonstrate a legitimate interest (in preventing/combating money laundering and terrorist financing); previously any person could request UBO data. Open public access has ended. Note: outdated trackers still list it as publicly accessible, but Romanian legal sources confirm the legitimate-interest restriction is in force.", "legalBasis": "Law 86/2025 amending Law 129/2019 (AML/CTF law), restricting access to those with legitimate interest in response to the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20). Restriction effective around May 2025.", "keyDate": "2025-05", "sourceUrl": "https://blog.pwc.ro/2025/11/20/accesul-la-datele-privind-beneficiarii-reali-ai-companiilor-din-romania-limitat-in-urma-unei-decizii-a-cjue/", "sourceTitle": "Accesul la datele privind beneficiarii reali ai companiilor din Romania, limitat in urma unei decizii a CJUE | PwC Romania", "confidence": "high" }, { "jurisdiction": "Saint Kitts and Nevis", "iso2": "KN", "registerName": "No publicly accessible beneficial-ownership register; UBO information held by registered agents and the Financial Services Regulatory Commission (FSRC)", "accessStatus": "never-public", "statusSummary": "Saint Kitts and Nevis does not provide public access to beneficial-ownership information. UBO data on legal persons and legal arrangements is collected and maintained by registered agents and supervised by the FSRC, and is accessible to competent authorities for AML/CFT and law-enforcement purposes. The Nevis regime expressly does not permit public access to beneficial ownership of companies registered under the Nevis Business Corporation Ordinance.", "legalBasis": "AML/CFT framework including the Anti-Money Laundering Regulations and the Nevis Business Corporation Ordinance 2017; supervised by the Financial Services Regulatory Commission", "keyDate": "2017-01-01", "sourceUrl": "https://www.openownership.org/en/map/country/saint-kitts-and-nevis/", "sourceTitle": "Open Ownership — Saint Kitts and Nevis country profile (cross-checked with FSRC beneficial-ownership pages and FATF/CFATF mutual-evaluation reporting)", "confidence": "high" }, { "jurisdiction": "Samoa", "iso2": "WS", "registerName": "No public register; BO information held by Trustee Companies/Service Providers and reported to SIFA", "accessStatus": "never-public", "statusSummary": "Samoa does not maintain a publicly accessible beneficial ownership register and keeps no public registers of directors or shareholders. Under the Trustee Companies Act 2017, trustee companies and TCSPs must keep beneficial ownership information and report changes; information filed with the Samoa International Finance Authority (SIFA) is maintained but not public. Access is for competent authorities and information-exchange purposes.", "legalBasis": "Trustee Companies Act 2017; International Companies Act 1988 / related SIFA framework", "keyDate": "2017-01-01", "sourceUrl": "https://www.oecd.org/content/dam/oecd/en/publications/reports/2019/11/global-forum-on-transparency-and-exchange-of-information-for-tax-purposes-samoa-2019-second-round_bc3b06e4/d8954bf5-en.pdf", "sourceTitle": "Global Forum on Transparency and Exchange of Information for Tax Purposes: Samoa 2019 (Second Round, OECD)", "confidence": "high" }, { "jurisdiction": "Seychelles", "iso2": "SC", "registerName": "Seychelles Beneficial Ownership Database (central register maintained by the Financial Intelligence Unit)", "accessStatus": "never-public", "statusSummary": "Seychelles maintains a centralised beneficial-ownership database held by the Financial Intelligence Unit (FIU), populated via resident agents. As of 2026 it is not open to the public; access is limited to competent authorities (FIU, Financial Services Authority, Registrar, Central Bank, law enforcement, courts). A 2024-announced reform is expanding access from 2026 to local banks and registered agents, but not to the general public.", "legalBasis": "Beneficial Ownership Act, 2020 and Beneficial Ownership Regulations, 2020 (in force 28 Aug 2020); s.13(1) BO Act tasks the FIU with maintaining the database", "keyDate": "2020-08-28", "sourceUrl": "https://seychellesfiu.sc/beneficial-ownership/", "sourceTitle": "Beneficial Ownership - Seychelles Financial Intelligence Unit", "confidence": "high" }, { "jurisdiction": "Singapore", "iso2": "SG", "registerName": "Register of Registrable Controllers (RORC) / Central Register of Controllers held by ACRA", "accessStatus": "never-public", "statusSummary": "Singapore has no public beneficial-ownership register. Companies and LLPs keep a private RORC, and since 30 July 2020 must also lodge the same particulars in ACRA's central RORC via BizFile+. Neither the private register nor ACRA's central register is open to the public: access is restricted to law enforcement agencies for administering/enforcing laws (e.g. AML investigations). The 16 June 2025 Corporate and Limited Liability Partnerships (Miscellaneous Amendments) reforms (CLLPMA) strengthened BO transparency and accuracy obligations but did NOT open the register to public access. CJEU has no application (Singapore is outside the EU).", "legalBasis": "Companies Act 1967, Part XIA (Register of Registrable Controllers; central RORC lodgement with ACRA) and the corresponding Limited Liability Partnerships Act provisions; access confined to law enforcement agencies. 2025 CLLPMA amendments (in force 16 June 2025) enhanced obligations but kept the register non-public.", "keyDate": "2020-07-30", "sourceUrl": "https://www.acra.gov.sg/compliance/register-of-registrable-controllers", "sourceTitle": "ACRA — Register of Registrable Controllers (RORC)", "confidence": "high" }, { "jurisdiction": "Slovakia", "iso2": "SK", "registerName": "Register pravnickych osob, podnikatelov a organov verejnej moci (RPO) - Register of Legal Entities (beneficial-ownership data)", "accessStatus": "closed-post-cjeu", "statusSummary": "Public access to beneficial-ownership data was technically and operationally discontinued on 10 July 2025 (external access blocked from 5 July 2025). Access is limited to public authorities, obliged entities and AML authorities. No legitimate-interest access framework for journalists/CSOs/persons with legitimate interest is yet in place - an amendment establishing such a framework is still in preparation - so the register remains genuinely closed to the public rather than reopened under legitimate-interest gating.", "legalBasis": "Act No. 272/2015 Coll. on the Register of Legal Entities, as amended by Act No. 302/2023 Coll., implementing the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20). Public access removed 10 July 2025; legitimate-interest framework still pending.", "keyDate": "2025-07-10", "sourceUrl": "https://www.hkv.sk/en/restriction-of-public-access-to-beneficial-ownership-data-in-the-register-of-legal-entities-implications-of-the-cjeu-judgment-and-legislative-consequences-for-slovakia/", "sourceTitle": "Restriction of Public Access to Beneficial Ownership Data in the Register of Legal Entities: Implications of the CJEU Judgment and Legislative Consequences for Slovakia | HKV Law Firm", "confidence": "high" }, { "jurisdiction": "Slovenia", "iso2": "SI", "registerName": "Beneficial Owner Register (Register dejanskih lastnikov, RDL), operated by AJPES", "accessStatus": "legitimate-interest-gated", "statusSummary": "Public access to the RDL was restricted by AJPES on 9 August 2025 to comply with the CJEU ruling; the register is now accessible to those who demonstrate a legitimate interest (e.g. journalists and CSOs), as defined in Articles 51 and 51a of the AML act, rather than the general public.", "legalBasis": "Prevention of Money Laundering and Terrorist Financing Act amendments (ZPPDFT-2C), implementing the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20) and AMLD6 legitimate-interest access", "keyDate": "2025-08-09", "sourceUrl": "https://sibiz.eu/slovenia-restricts-public-access-to-beneficial-owner-register-following-european-court-of-justice-ruling/", "sourceTitle": "Slovenia Restricts Public Access to Beneficial Owner Register Following European Court of Justice Ruling", "confidence": "high" }, { "jurisdiction": "South Africa", "iso2": "ZA", "registerName": "CIPC Beneficial Ownership Register (Companies and Intellectual Property Commission)", "accessStatus": "partial-or-other", "statusSummary": "South Africa operates a centralised beneficial-ownership register maintained by the Companies and Intellectual Property Commission (CIPC), which became operational on 1 April 2023 and to which more than 3 million BO declarations have been filed. As of 2026 the register is not open to the general public; access is restricted to law enforcement agencies and regulators, who must apply for access. The CIPC Commissioner has publicly advocated amending the law to make it an open register, but no such change had taken effect as of 2026.", "legalBasis": "General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act 22 of 2022, amending the Companies Act 71 of 2008", "keyDate": "2023-04-01", "sourceUrl": "https://www.cipc.co.za/?page_id=16055", "sourceTitle": "CIPC — Beneficial Ownership", "confidence": "high" }, { "jurisdiction": "Spain", "iso2": "ES", "registerName": "Central Registry of Beneficial Ownership (Registro Central de Titularidades Reales, RCTIR)", "accessStatus": "legitimate-interest-gated", "statusSummary": "Spain's RCTIR is accessible to authorities, obliged entities and persons demonstrating a legitimate interest; media outlets and civil-society organisations working on AML/CTF are presumed to have legitimate interest and may designate up to three individuals to access the register. Open general public access was not provided, consistent with the post-CJEU framework.", "legalBasis": "Real Decreto 609/2023 (11 July 2023, in force 19 Sep 2023), creating the RCTIR and regulating legitimate-interest access; reflects the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20) and AMLD6", "keyDate": "2023-09-19", "sourceUrl": "https://www.boe.es/buscar/act.php?id=BOE-A-2023-16159", "sourceTitle": "BOE-A-2023-16159 Real Decreto 609/2023, de 11 de julio, por el que se crea el Registro Central de Titularidades Reales", "confidence": "high" }, { "jurisdiction": "Sweden", "iso2": "SE", "registerName": "Beneficial Ownership Register (register over verkliga huvudman), operated by Bolagsverket", "accessStatus": "legitimate-interest-gated", "statusSummary": "After the CJEU ruling Sweden ended open public access; Bolagsverket now grants access to those who demonstrate a legitimate interest, with Transparency International noting general access is granted once legitimate interest is proven (instant access via eID, no charge). Underlying data is collected under the BO Act (2017:631).", "legalBasis": "Act on the Registration of Beneficial Owners (Lag 2017:631), with access restricted following the 22 Nov 2022 CJEU judgment (joined cases C-37/20 and C-601/20) and the AMLD6 legitimate-interest regime", "keyDate": "2022-11-22", "sourceUrl": "https://www.transparency.org/en/news/countdown-to-new-eu-beneficial-ownership-rules", "sourceTitle": "Countdown to new EU beneficial ownership rules: Testing progress on access", "confidence": "medium" }, { "jurisdiction": "Switzerland", "iso2": "CH", "registerName": "Federal Register of Beneficial Owners (Transparency Register / Eidgenoessisches Register der wirtschaftlich Berechtigten), under the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LETA / TJEA)", "accessStatus": "never-public", "statusSummary": "Switzerland is establishing a centralized federal beneficial-ownership (transparency) register under LETA, adopted by Parliament on 26 September 2025 and expected to enter into force around mid-2026 (implementing ordinance LETO out for consultation late 2025/early 2026). The register is explicitly NOT accessible to the public, whether on an open-access basis or under a legitimate-interest regime. Access is limited to designated authorities (criminal prosecution, tax, MROS, SECO, intelligence, AML supervisors, procurement and social-security bodies) and to AML-obliged financial intermediaries for their own due-diligence purposes. As a non-EU state, Switzerland was never bound by the EU AMLD public-register model nor by the 22 Nov 2022 CJEU judgment; it has simply never operated a publicly accessible BO register.", "legalBasis": "Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LETA / TJEA), adopted by the Swiss Parliament on 26 September 2025; implementing ordinance (LETO) in consultation, expected entry into force ~second half of 2026. Register access restricted by statute to authorities and AML-obliged intermediaries; no public or legitimate-interest access channel.", "keyDate": "Adopted 26 September 2025; expected entry into force ~mid/second-half 2026 (date to be set by Federal Council)", "sourceUrl": "https://www.lenzstaehelin.com/news-and-insights/browse-thought-leadership-insights/insights-detail/introduction-of-a-federal-register-of-beneficial-owners/", "sourceTitle": "Lenz & Staehelin - Introduction of a Federal Register of Beneficial Owners (Switzerland, LETA)", "confidence": "high" }, { "jurisdiction": "Ukraine", "iso2": "UA", "registerName": "Unified State Register of Legal Entities, Individual Entrepreneurs and Public Associations (USR), Ministry of Justice", "accessStatus": "public-open", "statusSummary": "Beneficial-ownership data in the USR is publicly searchable for free with no account at usr.minjust.gov.ua and is published as open data; Ukraine was a global first-mover on public BO transparency. Public access (interrupted by a December 2024 cyberattack) was restored and is operational as of 2026. Ukraine is not an EU member, so the CJEU judgment does not apply.", "legalBasis": "Law of Ukraine 'On State Registration of Legal Entities, Individual Entrepreneurs and Public Associations' (2014) and AML Law No. 361-IX 'On Prevention and Counteraction to Legalization (Laundering) of Proceeds of Crime...' (in force Apr 2020), aligned to FATF Recommendation 24.", "keyDate": "2017-01", "sourceUrl": "https://www.openownership.org/en/publications/early-impacts-of-public-beneficial-ownership-registers-ukraine/ukraines-pioneering-approach/", "sourceTitle": "Ukraine's pioneering approach | Open Ownership", "confidence": "high" }, { "jurisdiction": "United Arab Emirates", "iso2": "AE", "registerName": "Beneficial Owner (UBO) Register, maintained by UAE licensing/registrar authorities (mainland: Department of Economy/Ministry of Economy; free zones: respective free-zone authorities)", "accessStatus": "never-public", "statusSummary": "The UAE's beneficial-ownership (UBO) register is confidential and NOT publicly accessible or searchable. UBO data is held by the registrar/licensing authority and disclosed only to UAE competent government authorities (e.g. Central Bank, Federal Tax Authority, Ministry of Economy, law enforcement) upon official request, or with the UBO's consent or by judicial order. There is no public or legitimate-interest access channel and no announced commitment to make the register public. As a non-EU jurisdiction, the 22 Nov 2022 CJEU judgment does not apply; the UAE operates a regulator-only ('regulator-first') disclosure model consistent with FATF recommendations and has never had a public BO register.", "legalBasis": "Cabinet Decision No. 109 of 2023 Regulating the Beneficial Owner Procedures (effective 6 November 2023), building on Cabinet Resolution No. 58 of 2020 on the Regulation of the Procedures of the Real Beneficiary. Register access restricted by these instruments to competent authorities; disclosure otherwise requires UBO/nominee consent or a judicial order.", "keyDate": "Cabinet Decision No. 109 of 2023 effective 6 November 2023 (superseding/building on Cabinet Resolution No. 58 of 2020)", "sourceUrl": "https://nomadlaw.com/faq/corporate/is-the-information-about-uae-ubo-publicly-available/", "sourceTitle": "Nomad Law - UAE Ultimate Beneficial Owners Registry: is it public?", "confidence": "high" }, { "jurisdiction": "United Kingdom", "iso2": "GB", "registerName": "Register of People with Significant Control (PSC register), Companies House", "accessStatus": "public-open", "statusSummary": "Anyone can search and download PSC (beneficial-ownership) data for free via the Companies House public register and API, with no account or identity check required. The UK is outside the EU, so the 22 Nov 2022 CJEU judgment did not restrict access; residential address and full date of birth are redacted from the public view as standard data protection, but the register itself remains fully open.", "legalBasis": "Small Business, Enterprise and Employment Act 2015 (PSC regime; Companies Act 2006 Part 21A); Economic Crime and Corporate Transparency Act 2023 reforms (identity verification) phasing in through Nov 2026. Not subject to the EU AMLD framework or the CJEU judgment (post-Brexit).", "keyDate": "2016-06", "sourceUrl": "https://find-and-update.company-information.service.gov.uk/", "sourceTitle": "Search the register - Find and update company information - GOV.UK", "confidence": "high" }, { "jurisdiction": "United States", "iso2": "US", "registerName": "FinCEN Beneficial Ownership Information (BOI) registry", "accessStatus": "never-public", "statusSummary": "The BOI registry has never been open to the general public; the Corporate Transparency Act establishes it as a confidential database accessible only to authorized users (federal/state/local/tribal law enforcement and security agencies, qualifying foreign authorities, financial institutions with reporting-company consent, and Treasury). A March 2025 interim final rule further exempted all U.S.-formed entities and U.S. persons from reporting, leaving only foreign reporting companies obligated to file.", "legalBasis": "Corporate Transparency Act 2021 (31 U.S.C. 5336); FinCEN Beneficial Ownership Information Access and Safeguards Final Rule; Reporting Requirement Revision interim final rule, 26 Mar 2025 (90 FR / RIN 1506-AB49). Not an EU jurisdiction; the CJEU judgment does not apply.", "keyDate": "2025-03-26", "sourceUrl": "https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us", "sourceTitle": "FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov", "confidence": "high" }, { "jurisdiction": "Vanuatu", "iso2": "VU", "registerName": "VFSC beneficial-ownership register (Vanuatu Financial Services Commission)", "accessStatus": "never-public", "statusSummary": "Vanuatu requires ultimate beneficial owner information to be reported to the Vanuatu Financial Services Commission (VFSC) for local companies, but this beneficial ownership data is not a public register; it is held for competent-authority access. Vanuatu law prohibits disclosure of a company's shareholding, beneficial ownership, and related affairs by any person except under a court order. The VFSC's public entity search provides only basic company information, not beneficial ownership.", "legalBasis": "Companies Act No. 25 of 2012 and related VFSC beneficial ownership requirements; UBO reporting notice (2025)", "keyDate": "2025-06-03", "sourceUrl": "https://www.vfsc.vu/public-notices/", "sourceTitle": "VFSC Public Notices - Ultimate Beneficial Owner(s) for Local Companies", "confidence": "medium" } ] }