DarkRegister

Closed to the public (2)

Public access was suspended after the 2022 CJEU ruling and no functioning legitimate-interest channel has replaced it.

• Cyprussource

  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).

  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. · 2023-01-03

• Slovakiasource

  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.

  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. · 2025-07-10

Legitimate-interest gated (23)

General public access was withdrawn after the 2022 CJEU ruling; the register reopened only to authorities, obliged entities, and persons with a demonstrated legitimate interest (journalists, civil society, researchers) under AMLD6.

• Austriasource

  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.

  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. · 2025-10-01

• Belgiumsource

  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.

  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. · 2023-02-08

• British Virgin Islandssource

  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.

  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. · 2026-04-01

• Cayman Islandssource

  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.

  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. · 2026-03-18

• Czechiasource

  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.)

  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). · 2025-12-17

• Denmarksource

  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.

  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. · 2025-09-01

• Estoniasource

  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.

  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). · 2026-01

• Finlandsource

  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.

  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). · 2022-11

• Francesource

  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.

  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). · 2024-07-31

• Germanysource

  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.

  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. · 2022-11-22

• Greecesource

  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.

  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. · 2022-12-01

• Hungarysource

  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).

  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. · 2023

• Irelandsource

  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.

  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. · 2023-06

• Lithuaniasource

  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.

  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. · 2022-11

• Luxembourgsource

  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).

  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). · 2025-02-01

• Maltasource

  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).

  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. · 2025-07-10

• Netherlandssource

  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.)

  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. · 2025-07-15

• Norwaysource

  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.

  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. · Mandatory registration deadline 31 July 2025 (voluntary filing opened 1 October 2024); access framework shaped after the 22 November 2022 CJEU ruling

• Portugalsource

  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.

  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). · 2025-10-27

• Romaniasource

  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.

  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. · 2025-05

• Sloveniasource

  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.

  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 · 2025-08-09

• Spainsource

  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.

  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 · 2023-09-19

• Swedensource

  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).

  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 · 2022-11-22

Partial / restricted (8)

Access is restricted in a way that does not fit the other categories — e.g. nominally public but gated behind a national e-ID that excludes the general or foreign public.

• Australiasource

  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).

  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. · 2025-01-01

• Bermudasource

  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.

  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. · 2025-11-03

• Croatiasource

  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.

  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. · 2022-11-22

• Guernseysource

  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.

  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. · 2026-02-27

• Isle of Mansource

  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.

  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. · 2025-01-01

• Italysource

  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).

  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. · 2024-05-17

• Jerseysource

  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.

  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. · 2025-02-24

• New Zealandsource

  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).

  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. · 2025-12-20

Never public (6)

No general-public beneficial-ownership register exists; access was always limited (for example, the US registry was never public).

• Hong Kongsource

  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).

  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. · 2018-03-01

• Panamasource

  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.

  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. · 2020-03-17

• Singaporesource

  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).

  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. · 2020-07-30

• Switzerlandsource

  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.

  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. · Adopted 26 September 2025; expected entry into force ~mid/second-half 2026 (date to be set by Federal Council)

• United Arab Emiratessource

  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.

  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. · Cabinet Decision No. 109 of 2023 effective 6 November 2023 (superseding/building on Cabinet Resolution No. 58 of 2020)

• United Statessource

  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.

  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. · 2025-03-26

Public — open (7)

Anyone can access beneficial-ownership data, online and without demonstrating a special interest.

• Bulgariasource

  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.

  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. · 2025-06-04

• Canadasource

  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.

  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. · 2024-01-22

• Gibraltarsource

  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.

  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. · 2026-02-23

• Latviasource

  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.

  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. · 2024-04-19

• Polandsource

  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.

  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. · 2026-07-01

• Ukrainesource

  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.

  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. · 2017-01

• United Kingdomsource

  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.

  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). · 2016-06

The open ownership graph that survives

As public registers close, one open layer persists: the GLEIF Global LEI index. It records legal-entity-to-legal-entity ownership (which company owns which), is published under CC0, and concerns entities, not people — so it is safe to preserve and mirror in full. Across the 46 jurisdictions DarkRegister tracks, GLEIF already carries 2,743,585 legal entities, part of a 3,348,917-entity global index. DarkRegister captures this open coverage as the counterweight to the closures; the full CC0 golden copy can be mirrored to preserve the ownership graph itself.

• United States · Never public354,005 LEIs
• Italy · Partial / restricted253,418 LEIs
• Germany · Legitimate-interest gated250,733 LEIs
• United Kingdom · Public — open227,973 LEIs
• Netherlands · Legitimate-interest gated191,351 LEIs
• Spain · Legitimate-interest gated190,399 LEIs

Legal-entity counts from the GLEIF API (CC0), 2026-06-22. Entity counts only — no personal data.

What this is — and what it is not

DarkRegister v0 documents register-access policy: the public, citable fact of whether a country's beneficial-ownership register is open, gated, or closed, with the legal basis and a source. It deliberately publishes no beneficial-owner identities — no names, no addresses, no personal data. The CJEU ruling restricted general-public access to individuals' data; a record of which registers closedis a statement about government transparency, not a re-publication of anyone's personal information. See the methodology for the access taxonomy and the privacy design.